\ 


UNIVERSITY  OF  CALIFORNIA. 


Q 


A) 


C/asx 


United  States  Supreme  Court 


STATE  OF  MISSOURI 

vs. 

STATE  OF  ILLINOIS  AND 

THE  SANITARY  DISTRICT  OF  CHICAGO 


TESTIMONY  OF 

JOHN  W.  ALVORD 

Sanitary  and  Hydraulic  Engineer  of  Chicago,  111 

TAKEN  BEFORE 

HON.  F.  S.  BRIGHT 

Commissioner 


AT  THE  SOUTHERN  HOTEL,  ST.  LOUIS,  MAY  25th  AND  26th 

1904 


TRIBUNF  PTQ.  CO.,  JTFFtRSON   CITY 


United  States  Supreme  Court 


STATE  OF  MISSOURI 


vs. 


STATE  OF  ILLINOIS  AND 

THE  SANITARY  DISTRICT  OF  CHICAGO 


TESTIMONY  OF 


JOHN  W.  ALVORD      '  *  - 

Sanitary  and  Hydraulic  Engineer  of  Chicago,  111, 


TAKEN  BEFORE 


HON.  F,  S.  BRIGHT 

Commissioner 


AT  THE  SOUTHERN  HOTEL,  ST.  LOUIS,  MAY  25th  AND  26th 

1904 


TRIBUNE  PTQ.  CO.,  JEFFERSON  CITY 


0^ 

<-v«) 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.          >'> 

JOHN  W.  ALVORD, 

a  witness  called  on  behalf  of  the  complainant,  being  duly  sworn 
by  the  Commissioner,  was  examined  in  chief  by  Mr.  Jeffries, 
and  testified  as  follows: 

Q.     Please  state  your  full  name  and  address! 

A.     John  W.  Alvord. 

Q.     Also  your  occupation! 

A.     Sanitary  and  Hydraulic  Engineer,  Chicago,  Illinois. 

Q.  How  long  have  you  been  engaged  in  the  practice  of 
your  profession  as  a  hydraulic  and  sanitary  engineer! 

A.     About  twenty-four  years. 

Q.     Where? 

A.  With  Chicago  as  a  center,  in  and  about  Chicago  and  the 
middle  west. 

Q.  Mr.  Alvord.  give  an  outline  in  a  general  way  of  your 
educational  training! 

A.     I  was  ready  for  entrance  to  the  Sheffield  Scientific 

12834  School  of  Yale  College  in  1877,  but  was  unable  to  take 
the  course  owing  to  poor  health.    My  engineering  educa- 
tion has  therefore  been  confined  to  study  and  travel,  coupled 
with  practical  experience.    The  first  engineering  work  in  which 
I  was  engaged  was  in  1879  in  Chicago  in  connection  with  th<> 
construction  of  the  Hyde  Park  Pumping  Station  of  the  Chicago 
water  works  and  the  Inlet  tunnel  to  such  station  under  Lake 
Michigan. 

Later,  I  was  in  charge  of  the  operation  of  the  Lake  View 
Station  of  the  Chicago  water  works,  and  was  for  four  years 
City  Engineer  of  Lake  View,  then  a  separate  municipality  from 
the  city  of  Chicago,  since  annexed. 

After  the  annexation  of  Lake  View  I  engaged  in  general 
practice  in  ^sanitary  work  in  the  suburbs  of  Chicago  and  ad- 
jacent cities. 

I  visited  Europe  in  1888  and  1894  and  examined  the  ques 
tion   of   water   purification   and   sewage  disposal  particularly. 
From  1890  to  1893  I  had  charge  of  a  department  in  the  con- 
struction of  the  World's  Columbian  Exposition  at  Chi- 

12835  ea£o  and  in  1894  resumed  private  practice,  since  whic-ft 
time   T  have  been  engaged   in   various  capacities  with 


4  The  State  of  Missouri  vs. 

about  thirty-five  different  city  water  works  plants  and  about 
forty-five  municipal  sewer  systems,  including  the  purification  of 
water  supplies  and  the  disposal  of  sewage.  I  was  engaged  in 
1898  in  making  a  report  to  the  city  of  Columbus,  Ohio,  on  the 
extension  of  its  sewer  system  and  the  disposal  of  its  sewage, 
which  report  was  published. 

From  1898  to  1902  I  was  consulting  engineer  to  the  Illinois 
State  Canal  Commission,  advising  as  to  the  works  of  the  sani- 
tary district  channel  in  and  through  Joliet  and  in  the  litigation 
as  to  the  removal  of  dams  and  locks  at  Joliet. 

I  have  been  engaged  recently  in  the  development  of  water 
power  at  Petosky,  Michigan,  and  Big  River,  Missouri,  and  Des 
Moines,  Iowa.  I  have  been  engaged  in  the  design  of  some  twelve 
water  works  plants  which  have  been  constructed  and  in  which 
the  question  of  river  pollution  bore  an  active  part, 

I  have  had  some  limited  experience  in  typhoid  epidemics, 
having  studied  them  at  Hurley,  Wisconsin;  Ironwood 

12836  Michigan,  and  Culver  Academy,  Indiana  in  1894,  and  tho 
typhoid  epidemic  of  Chicago  in  1892  and  1893,  the  Du- 

luth  epidemic  of  1896,  the  typhoid  epidemic  at  Grand  Forks, 
North  Dakota,  in  1894,  and  was  engaged  to  investigate  the  causes 
of  the  epidemic  at  Wequetonsing,  Michigan,  and  Petosky,  Mich- 
igan, in  1903. 

Q.  State  whether  or  not  the  epidemics  that  you  have  re- 
ferred to  were  caused  by  water  in  any  case? 

A.  So  far  as  I  have  studied  them  they  were  all  caused  by 
polluted  water  supplies. 

Q.  Are  you  familiar  with  the  Chicago  river,  the  drainage 
canal,  the  Desplaines  and  the  Illinois  river? 

A.  I  am.  In  1888  I  was  engaged  in  conducting  the  litiga- 
tion in  behalf  of  the  State  of  Illinois  with  the  Sanitary  District, 
in  the  course  of  which  the  hydraulics  of  the  upper  portion  of  the 
Desplaines  river  were  thoroughly  reviewed.  I  have  studied  in 
general  the  progress  of  the  construction  of  the  drainage  chan- 
nel and  the  related  questions,  and  was  engaged  in  working  for 
the  special  commission  which  reported  upon  its  eom- 

12837  pletion. 

I  have  observed  the  Illinois  river  at  Morris,  111.,  where  I 
designed  the  system  of  sewers ;  at  Ottawa,  where  I  was  engaged 
in  water  power  litigation;  at  Marseilles,  where  I  advised  a.s 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.          5 

to  the  enlargement  of  the  water  power,  and  have  also  observed 
the  general  characteristics  of  the  river  at  Seneca,  La  Salle,  Peru, 
Hennepin,  Peoria,  Pekin  and  Havana,  at  which  latter  two  places 
I  have  designed  sewerage  systems. 

1  am  also  familiar  witJi  the  Mississippi  river  from  St.  Louis 
to  Alton,  to  some  extent. 

Q.  State  whether  or  not  you  are  familiar  with  the  ordinary 
minimum  flow  of  the  Illinois  river  before  and  since  the  opening 
of  the  drainage  canal  "I 

A.  I  have  had  occasion  to  observe  at  different  times  be- 
fore the  opening  of  the  drainage  channel  the  flow  of  the  Illinois 
and  the  lower  Desplaines  river,  arid  have  also  observed  it  since 
the  opening  of  the  drainage  channel. 

Q.  Mr.  Alvord,  state  whether  or  not  you  have  given  the  sub- 
ject of  bacteriology  any  attention  in  connection  with  your 

12838  profession  ? 

A.  I  have  to  a  limited  extent.  I  have  tried  to  keep 
myself  posted  upon  bacteriology  in  a  general  way  ever  since  it 
has  come  into  use  among  engineers. 

Q.  Now  state  whether  or  not  you  have  familiarized  your- 
self with  the  subject  of  chemistry  as  applied  to  your  profession! 

A.  Also  to  a  limited  extent.  I  took  a  partial  course  in 
chemistry  at  the  University  of  Chicago  in  1894.  In  1900  I 
studied  bacterial  quantitative  analysis  under  the  advice  of  Pro- 
fessor Novy  of  Ann  Arbor,  Michigan.  I  have  endeavored  to  keep 
info nned  on  the  subject  in  everything  which  would  be  of  inter- 
est to  iny  work  as  a  sanitary  engineer. 

Q.  State  whether  or  not  you  were  ever  engaged  with  the 
water  investigations  of  the  city  of  St.  Louis! 

A.     I  was  employed  in  1902  by  the  special  commission  that 

investigated  the  extension  of  the  water  supply  of  the  city  of  St. 

Louis,  and  my  part  of  the  work  was  to  study  the  financial  history 

of  the  present  works,  their  physical  cost  and  the  cost  of  their 

operation.    In  the  course  of  this  work  I  became  familiar 

12839  with  the  characteristics  of  these  works  and  have  visited 
the  Chain  of  Kocks  stations  and  sedimentation  basins, 

also  the  old  station  at  BissePs  Point,  and  have  studied  the  phy- 
sical features  of  the  sedimentation  plant. 

Q.     State  whether  or  not  you  have  made  any  special  study 


6  The  State  of  Missouri  vs. 

of  the  typhoid  condition  on  the  water  shed  of  the  river  above 
St.  Louis? 

A.     To  some  extent. 

Q.  "Where  did  you  obtain  the  data  which  you  have  in  regard 
to  the  typhoid  deaths  and  the  population  of  these  water  sheds? 

A.     From  the  records  in  this  case. 

Q.     From  evidence  introduced  by  the  respondents? 

A.    Yes  sir. 

Q.     And  complainants! 

A.     Yes  sir. 

Q.  State  whether  or  not  you  have  prepared  a  diagram' 
showing  the  relations  of  typhoid  fever  deaths  in  St.  Louis  with 
typhoid  deaths  on  the  water  sheds? 

A.    I  have. 

Q.     Will  you  submit  this  diagram? 

A.     I  will. 

12841  ME,  JEFFRIES:  Q.  I  will  ask  you,  Mr.  Alvord, 
whether  or  not  this  'diagram  is  based  upon  the  typhoid 
fever  deaths  upon  the  water  sheds  of  the  Mississippi,  the  Illinois 
and  the  Missouri  rivers  respectively,  as  shown  by  a  tabulated 
sheet  of  the  evidence  upon  that  subject,  introduced  in  this  case? 

A.    It  is. 

MR.  JEFFRIES:  I  now,  Mr.  Commissioner,  offer  this 
diagram  in  evidence. 

The  diagram  is  as  follows : 


The  State  of  Illinois  and  the  Sqnitary  District  of  Chicago.         7 
12842  Complainant's  Rebuttal  Chart  No.  1. 


Diagram  Show/net 
RELATION  **  TYPHOID  DEJTHS'z,5T.kv/5 


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Chicago 


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8  The  State  of  Missouri  vs. 

THE  COMMISSIONER:  This  diagram  is  known  in  evi- 
dence as  complainant's  rebuttal  chart  number  1. 

MB.  JEFFRIES:  Q.  Please  explain  this  chart  or  dia- 
gram? 

A.  The  data  from  which  the  diagram  is  plotted  are  shown 
in  a  table  of  seven  columns,  in  the  upper  left  hand  corner.  The 
first  column  which  gives  the  year  in  which  the  deaths  occurred, 
the  second  column  showing  the  total  typhoid  deaths  in  St.  Louis 
for  each  given  year,  the  third  column  showing  the  population 
of  St.  Louis  for  each  given  year,  taken  from  the  Federal  Census 
for  the  years  1890  and  1900,  and  the  Federal  estimated  census 
for  the  years  1901  and  1902,  and  estimated  complete  for  the  re- 
maining years,  such  estimate  being  made  at  the  proportional 
rate  of  increase  to  the  figures  of  the  Federal  census  and  the 
Federal  estimates. 

12844  The  fourth  column  gives  the  typhoid  death  rate  in  St. 
Louis  per  500,000  population,  being  reduced    to  that 

standard  population  for  the  years  as  given. 

The  fifth  column  gives  the  typhoid  deaths  on  all  of  the 
water  sheds  above  St.  Louis,  taken  from  the  records  in  this 
case  above  referred  to  and  excluding  the  sanitary  district  of 
Chicago. 

The  sixth  column  gives  the  typhoid  deaths  in  the  city 
of  Chicago  for  the  years  1900,  1901  and  1902,  as  taken  from  the 
record  in  this  case  above  referred  to,  and  the  seventh  column 
gives  the  deaths  from  typhoid  for  all  of  the  water  sheds 
above  St.  Louis,  including  the  Sanitary  District  of  Chicago,  as 
taken  from  the  records  in  this  case  above  referred  to. 

The  diagram  is  plotted  so  that  the  ordinates  represent  the 
total  typhoid  deaths,  the  abscissa  the  years  from  1890  to  1902, 
inclusive,  in  which  such  deaths  occurred.  The  lower  dotted  line 
of  the  diagram  marked  deaths  on  the  Illinois  water  shed  shows 
the  deaths  on  the  Illinois  water  shed,  excluding  the  drainage  dis- 
trict for  the  years  1893  to  1900,  inclusive.  Above  this  line  will 
be  found  a  light  dash  and  dotted  line  marked  Missouri 

12845  water  shed,  which  gives  the  total  typhoid  deaths  on  the 
Missouri  water  shed  for  the  years  1895  to  1902,  inclusive. 

Above  this  line  again  will  be  found  a  light  dash  line  marked 
deaths  on  the  Mississippi  water  shed  which  gives  the  typhoid 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.          9 

deaths  on  the  Mississippi  river  above  St.  Louis  for  the  years 
1893  to  1902,  inclusive. 

Above  this  line  again  will  be  found  a  heavy  dash  line  marked 
total  deaths  above  St.  Louis,  exclusive  of  Chicago,  which  gives 
the  total  typhoid  deaths  on  the  three  combined  rivers  above  St. 
Louis  for  the  years  1893  to  1902,  inclusive,  excluding  the  San- 
itary District  of  Chicago. 

In  January,  1900,  the  drainage  channel  was  opened,  adding 
the  discharge  of  the  sanitary  district  of  Chicago  to  the  last  de- 
scribed line.  This  is  shown  on  the  diagram  by  a  line  extending 
vertically  upward  from  the  last  described  line  to  the  year  1900 
and  plotted  of  such  a  length  so  that  it  shows  the  total  deaths 
from  typhoid  in  that  year  in  the  sanitary  district  of  Chicago 
which  is  added  to  the  tqtal  typhoid  deaths  on  all  the  water  sheds. 
This  heavy  dashed  line,  marked  on  the  diagram  "  Chicago 
12846  added,"  extends  diagonally  upward  from  the  year  1900 
through  the  years  1901  and  1902,  being  in  each  case  plotted 
so  that  the  total  typhoid  deaths  in  the  sanitary  district  of  Chicago- 
are  added  to  the  total  deaths  on  the  line  marked  total  deaths 
above  St.  Louis,  exclusive  of  Chicago,  and  shows  the  total  deaths 
on  all  water  sheds  including  the  sanitary  district  of  Chicago. 
The  heavy  line  on  the  diagram  marked  "Deaths  in  St.  Louis 
per  500,000  inhabitants,"  shows  the  typhoid  deaths  in  St.  Louis 
taken  from  the  records  in  this  case  above  referred  to  for  the 
years  1890  to  1903,  inclusive,  the  dotted  line  leaving  this  heavy 
black  line  in  the  year  1898  and  rejoining  it  again  in  the  year 
1901  shows  a  correction  made  by  deducting  certain  deaths  due 
to  a  localized  milk  epidemic  described  by  Professor  Sedgwick 
and  Mr.  Loch  ridge. 

ME.  JEFFRIES:  Q.  Mr.  Alvord,  state  what  conclusions 
you  draw  from  this  diagram? 

A.  It  has  been  the  endeavor  in  this  diagram  to  disclose 
the  causes  for  the  increase  in  typhoid  deaths  in  St.  Louis  during 
the  last  few  years.  In  order  to  intelligently  determine  such 
causes,  the  typhoid  deaths  along  the  different  rivers  have  been 
separated  from  each  other  arid  platted  separately  so  as  to  de- 
termine the  source  of  the  most  marked  pollution.  It  will  be  seen 
that  the  deaths  from  typhoid  on  the  Illinois  water  shed,  exclu- 
sive of  the  sanitary  district  of  Chicago,  are  fairly  uniform  up 
to  the  year  1899.  but  show  a  rise  in  the  year  1900,  the  year  in 


10  The  State  of  Missouri  vs. 

which  the  drainage  canal  was  opened.  Otherwise  they  seem  to 
be  fairly  uniform  for  the  years  preceding  and  following  the  com- 
mencement in  the  rise  in  the  number  of  typhoid  deaths  in  St. 
Louis. 

The  deaths  011  the  Missouri  river  water  shed  appear  also 
to  be  reasonably  uniform  for  the  period  under  consideration, 
and  the  typhoid  deaths  on  the  Mississippi  river  water  shed,  while 
fluctuating  somewhat  more  than  the  first  two  described,  are 
nevertheless  generally  uniform  before  and  near  the  rise  in  the 
typhoid  deaths  in  St.  Louis. 

In  summing  up  the  total  typhoid  deaths  on  the  water  shed 

above  St. 'Louis,  as  given  in  the  record,  it  would  appear 

12848    that  while  there  is  some  fluctuations  and  a  low  period 

about  the  year  1896  that  at  no  time  since  the  rise  in 

tphoid  deaths  in  St.  Louis  they  have  materially  exceeded  a  fair 

average  rate  and  have  in  fact  fallen  off  since  the  year  1900. 

It  will  be  observed,  however,  that  the  addition  of  the  deaths 
from  the  sanitary  district  almost  doubles  the  total  typhoid 
deaths,  influencing  the  pollution  of  the  St.  Louis  water  supply 
and  that  such  addition  is  materially  increased  during  the  years 
.1 901  and  1902,  so  that  in  1902  the  total  typhoid  deaths  are  nearly 
two  and  one-half  times  the  deaths  on  the  water  shed  above  St. 
Louis,  exclusive  of  the  sanitary  district  of  Chicago. 

A  local  epidemic  in  St.  Louis  typhoid  deaths  in  1892  is 
clearly  shown  by  the  diagram  and  is  attributable  to  the  con- 
tamination of  the  water  supply  at  the  old  station  at  Bissell,  by 
Ginras  Creek,  and  neighboring  sewers. 

Upon  the  removal  of  the  source  of  supply  from  Bissell's 
Point  to  the  chain  of  rocks  in  the  years  1894  to  1895  there  i.s 
shown  a  marked  improvement  in  the  total  number  of  deaths 
from  typhoid  for  the  latter  year. 

MB.  JEFFEIES:  Q.  What  cities  were  considered  by  you 
on  the  three  water  sheds  in  the  plotting  of  this  diagram? 

A.     Only  those  referred  to  in  the  records  of  this  case. 

Q.  I  will  ask  you  to  state  briefly,  if  you  know,  what  changes 
have  taken  place  in  the  conditions  of  the  water  in  the  Missis- 
sippi river  at  St.  Louis  since  the  removal  of  the  intake  from 
Bissell  ?s  Point  to  the  chain  of  rocks  in  1895? 

A.  The  sanitary  district  of  Chicago  opened  their  channel 
on  or  about  the  17th  of  January,  1900,  introducing  into  the  water 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        11 

shed  above  St.  Louis  a  large  additional  amount  of  water  and 
sewage. 

MR.  JEFFRIES :     Q.     State  whether  or  not  you  are  ac- 
quainted with  the  physical  conditions,  drainage  area  and  the  pop- 
ulation upon  the  water  sheds  of  the  Illinois,  the  Missis- 
12850     sippi  above  Graf  ton  and  the  Missouri  river. 
A.     In  a  general  way  I  am. 

Q.  Taking  into  consideration  the  evidence  introduced  in 
this  case  upon  the  typhoid  death  statistics  upon  the  water  sheds 
of  these  rivers,  and  all  evidence  in  connection  therewith.  I  will 
ask  you  to  state  to  what  do  you  attribute  the  increase  in  typhoid 
in  the  city  of  St.  Louis,  during  the  years  1900  to  1903,  inclusive? 

Q.     Question  read. 

A.     I  should  consider,  after  a  study  of  the  data  that  in  all 
human  probability  the  rise  in  typhoid  deaths  in  the  city  of  St. 
Louis  in  the  last  few  years  has  been  caused  by  the  added  typhoid 
contamination  from  the  sanitary  district  of  Chicago. 

MR.  JEFFRIES :  Q.  In  what  way,  Mr.  Alvord,  is  the 
longevity  and  vitality  of  typhoid  organisms  of  special  interest  to 
you  in  your  profession  as  a  sanitary  engineer! 

A.  In  advising  municipalities  as  to  the  purity  and  safety 
of  their  sources  of  water  supply. 

Q.  State  whether  or  not  you  are  familiar  with  and  have 
acquainted  yourself  with  the  literature  upon  this  subject! 

A.  I  have  endeavored  to  do  so  for  the  past 'fifteen  or  eigh- 
teen years. 

Q.     What  was  your  object  in  doing  so! 

A.  In  order  that  my  advice  to  municipalities  might  be  con- 
servative. 

•Q.  What  do  you  consider  in  your  practice  and  in  the  recom- 
mendations which  you  make  in  your  profession  as  a  fair  state- 
ment of  the  longevity  of  typhoid  organisms  which  would  lead 
you  to  give  what  you  consider  conservative  advice  upon  this  sub- 
ject! 

A.  I  have  for  some  years  past  considered  the  life  of  the 
typhoid  bacilli  would  be  from  sixty  to  ninety  days  under  favor- 
able environments,  and  while  large  masses  of  such  bacilli  might 
be  removed  from  any  given  source  of  supply  in  a  comparatively 
short  time  under  unfavorable  environments,  it  would  not  be  safe 
to  assume  that  a  water  once  thus  polluted  would  be  safe  to  rec- 


12  The  State  of  Missouri  vs. 

ommend  for  public  use  under  the  time  given,  unless  the  con- 
tamination were  eliminated  by  a  carefully  designed  and  properly 
operated  system  of  purification. 

ME.  JEFFRIES :  Q.  Are  you  familiar  with  the  results  of 
the  experiments  found  in  the  reports  of  the  Massachusetts  Board 
of  Health  in  which  Hiram  T.  Mills  presents  data  on  the  longe- 
vity of  typhoid  bacilli  in  the  waters  of  the  Merrimack  river 
which  results  were  obtained  by  him  upon  analysis  and  experi- 
ments conducted  by  him? 
A.  I  am. 

12853  Q.     Where,  if  any,  do  you  find  other  similar  experiments 
or  determinations? 

A  There  will  be  found  in  the  proceedings  of  the  Sanitary 
Institute  of  1899,  some  experiments  made  by  Dr.  Horrocks  which 
appear  to  be  similar  to  those  carried  out  by  Mr.  Mills.  These 
experiments  are  also  quoted  in  Mr.  Samuel  Rideal's  book  on 
sewage,  on  page  70. 

MR.  TODD :  Q.  Are  the  experiments  that  you  are  quoting 
the  experiments  of  Mills  1 

A.     No  sir,  Horrocks. 

MR.  JEFFRIES :  Q.  Are  you  familiar  with  the  sewerage 
system  of  Chicago! 

A.     I  am.    A  portion  of  it  has  been  constructed  under 

12854  my  design  and  supervision. 

Q.  Under  what  conditions  in  your  opinion  are  typhoid 
bacilli  carried  away  from  Chicago  so  as  to  approximate  condi- 
tions which  Mr.  Hiram  F.  Mills  and  Dr.  Horrocks  used  in  their 
experimental  work  ? 

A.  The  sewerage  system  of  Chicago  has  very  flat  gradients 
and  requires  frequent  artificial  flushing.  It  has  been  the  history 
of  heavy  rainfalls  in  that  city  that  the  entire  content  of  the 
sewers  are  at  such  times  disgorged  into  the  river  bringing  into  it 
a  mass  of  pollution  which  has  'been  accumulating  for  months  to- 
gether. Before  the  opening  of  the  drainage  channel  such  periods 
were  extremely  dangerous  to  the  water  supply  of  the  city,  as 
was  shown  in  the  increase  in  typhoid  deaths  following  the  period 
of  such  contamination.  Such  heavy  flushings  of  rainfall  occur 

ordinarily  in  the  early  spring  or  after  the  breaking  up  of 

12855  the  winter  and  at  times  when  the  temperature  is  most 
favorable  to  the  longevity  of  the  typhoid  germ  and  greatly 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        13 

increases  for  the  time  being  the  rate  of  pollution  in  the  drainage 
€anal  and  Desplaines  and  Illinois  rivers. 

In  my  opinion  the  action  of  such  a  flushing  of  the  Chicago 
sewer  system  into  the  Chicago  river  with  its  present  large  pro- 
portion of  pure  water  and  low  temperature  furnishes  conditions 
which  parallel  or  indeed  form  more  favorable  conditions  to  the 
longevity  of  pathogenic  bacteria  than  those  under  which  the  ex- 
perimental work  above  noted  were  taken.  The  discharge  of  this 
various  amount  of  pollution  at  times  of  flood  waters  appears 
also  to  furnish  the  necessary  velocity  for  rapid  conveyance 
through  the  drainage  canal  down  the  Desplaines  and  Illinois 
rivers-  to  the  intake  of  the  St.  Louis  water  supply ;  the  increment 
of  tributary  streams  also  increases  the  dilution  and  decreases 
the  chance  for  toxic  destruction  of  the  total  number  of  typhoid 
germs  present.  Such  conditions  are  prevalent  in  greater  or  less 
degree  during  many  times  of  each  spring. 

ME.  JEFFEIES :  Q.  In  what  you  have  said  of  the 
spring  flood,  do  you  have  reference  to  the  ordinary  spring  floods 
or  to  the  exceptional  floods  which  sometimes  occur  in  this  re- 
gion? 

A.  My  answer  refers  entirely  to  ordinary  conditions  such 
as  occur  perhaps  eight  or  ten  times  or  more  in  the  spring  of 
each  year  and  often  at  other  times  in  the  year,  rather  than  to  ex- 
ceptional floods  such  as  that  of  1888  or  1892  and  one  or  two 
other  heavy  floods  in  which  extreme  high  water  marks  were 
reached.  Such  floods  would  naturally  conduct  the  danger  from 
typhoid  pollution  to  greater  distances  from  the  source  or  origin. 

ME.  JEFFRIES :    Q.    Are  there  any  other  evidences  from 
the  testimony  introduced  in  this  case  and  which  you  have  ob- 
served which  would  increase  the  flow  above  that  men- 
12857     tioned  by  you? 

A.  Yes  sir,  in  the  case  of  heavy  rainfall  on  the  water 
slied  of  the  Chicago  river,  it  is  often  necessary  in  order  to  pre- 
vent outflow  into  Lake  Michigan  through  the  main  river,  to 
lower  the  Bear  Trap  Dam  at  Lockport  so  as  to  produce*  greater 
velocity  at  all  stations  down  the  channel  at  such  times.  This 
undoubtedly  aids  in  the  rapidity  with  which  pollution  is  con- 
veyed away  from  Chicago  down  the  channel  of  the  Desplaines 
and  Illinois  rivers. 


14  The  State  of  Missouri  vs. 

Q.  What  are  the  conditions  of  stream  flow  in  the  Desplaiues 
river! 

A.     Below  the  outlet  of  the  drainage  canal  at  Lockpnrt,  the 

Desplaines  river  flows  very  rapidly  to  a  pool  formed  by  wns:. 

is  known  as   dam  number  one  at  Joliet.     This   descent   over 

ordinary  and  normal  flow  produces  rapid  velocity  and 

12858  a  slight  rise,  from  rainfall  will  develop  velocity  in  the 
channel  of  from  40  to  60  miles  per  day. 

ME.  JEFFRIES:  Q.  What  are  the  conditions  of  flow  in 
the  Desplaines  and  Illinois  river  as  far  down  as  the  Marseilles 
dam"/ 

A.  Below  dam  number  one  and  at  Joliet  the  flow  again  be- 
comes very  rapid  at  times  of  moderate  rises.  This  flow  is 
slightly  checked  through  Lake  Joliet,  but  there  is  a  further 
rapidity  incurred  on  its  outlet  all  the  way  down  to  the  mouth  oT 
the  Kankakee  river.  Below  this  point  the  Marseilles  dam  slightly 
checks  the  current. 

Q.  What  are  the  conditions  of  flow  in  the  Illinois  river 
immediately  below  the  Marseilles  dam,  below  Marseilles  at 
Per  u  I 

A.  Another  rapid  flow  takes  place  below  the  Marseilles 
dam  as  far  down  as  to  Peru,  where  the  influence  of  the  Henry 
dam  is  felt. 

Q.     State  whether  or  not  that  is  especial Jy  true  in  time  oL' 

12859  spring  floods  or  rises? 

A.  In  the  time  of  spring  lises  the  velocity  in  these 
reaches  is  very  materially  increased,  running,  as  I  have  said,  up 
to  as  high  as  forty  to  sixty  miles  a  day. 

Q.  Are  you  familiar  with  the  testimony  of  Mr.  Randolph 
in  this  case? 

A.     I  have  read  Mr.  Randolph's  testimony. 

Q.  Taking  into  consideration  the  testimony  of  Mr.  Ran- 
dolph and  the  testimony  of  all  other  witnesses  affecting  the  sub- 
ject of  hydraulics  and  sanitary  engineering,  I  will  ask  you  to 
state,  Mr.  Alvord,  what  effect,  if  any,  has  the  discharge  of 
250,000  cubic  feet  of  water  per  minute  through  the  Chicago 
Drainage  Canal  upon  the  dangerous  and  deleterious  substances 
contained  in  the  sewage  discharged  into  the  Chicago  river  and 
the  drainage  canal? 

A.     The  effect  is  to  materially  increase  the  current  <>!'  th-1 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        15- 

Desplaines  and  Illinois  river  and  to  carry  dangerous  pollution 
to  greater  distances  and  with  more  rapidity. 

ME.  JEFFRIES:  Q.  Are  you  familiar  with  the  flow 
measurements  of  the  Chicago  river,  the  main  drainage  canal,  the 
Desplaines  river  and  the  Illinois  river  as  described  by  Mr.  Ran- 
dolph in  his  testimony? 

A.     I  have  studied  them. 

Q.  Do  you  know  the  discharge  of  the  river  at  the  time  these 
observations  were  made  under  Mr.  Randolph's  directions! 

A.  I  am  unable  to  find  anything  in  Mr.  Randolph's  tes- 
timony which  gives  any  clue  to  the  amount  of  discharge  in  the 
Desplaines  and  Illinois  river  either  at  Joliet  or  Peoria  and 
therefore  am  unable  to  determine  what  stage  the  river  was  in 
at  the  time  of  his  float  measurements.  The  times  of  these  ex- 
periments were  in  July,  1903,  as  appears  by  the  record  and  such 
time  is  not  covered  by  the  table  of  discharge  given  in  his  tes- 
timony at  Lockport,  nor  are  any  guage  readings  given  at 

12861  Peoria  where  the  testimony  includes  a  rating  table.     1 
only  find  the  statement  that  the  floats  passed  over  thi* 

distance  in  fifteen  days,  which  is  raised  to  eighteen  and  one- 
half  days  by  dividing  by  eight-tenths. 

Q.     What  distance  do  you  refer  to  in  your  last  answer! 

A.  The  distance  from  the  Chicago  river  to  the  chain  of. 
rocks  in  the  Mississippi  above  St.  Louis. 

Q.  As  a  hydraulic  engineer  state  whether  or  not  the  time 
limit  as  ascertained  by  the  floats  should  be  raised  in  the  man- 
ner indicated  by  Mr.  Randolph  in  his  testimony,  by  dividing 
by  .81? 

A.  I  fail  to  see  the  pertinency  of  his  conclusion  that  a 
correction  should  be  made,  tending  to  reduce  the  maximum  sur- 
face velocity  to  the  mean  velocity  of  flow.  The  use  of  the  . v 
correction,  in  the  manner  described  in  Mr.  Randolph's  testi- 
mony is  a  very  rough  approximation,  used  by  hydraulic  en- 
gineers when  surface  floats  are  run  in  the  most  rapid  part  of 
the  channel  of  a  river  to  determine  the  average  flow  for  the 
whole  cross  section  of  the  channel  in  order  to  get  at  the 

12862  quantity  passing  a  given  point  per  second.    In  the  case 
under  consideration,  we  are  not  endeavoring  to  deter- 
mine the  quantity  of  water  passing  any  given  cross  section  per 
second,  but  the  problem  presented  is  what  length  of  time  will 


16  The  State  of  Missouri  vs. 

any  given  pollution,  flowing  in  mid  channel,  pass  over  the  neces- 
sary distance  from  the  Chicago  river  to  the  chain  of  rocks.  This 
only  requires,  in  my  opinion,  a  determination  of  the  mean  veloc- 
ity of  the  bore  or  central  section  of  the  stream. 

Q.  Do  you  as  a  hydraulic  engineer  consider  the  floats  de- 
scribed by  Mr.  Randolph  and  Mr.  Crane  as  surface  floats! 

A.  I  should  not  consider  them  so.  As  described  in  the  tes- 
timony they  appear  to  he  partially  submerged  and  1  believe  they 
give  the  mean  velocity  of  the  central  portion  of  the  stream  with 
a  fair  degree  of  accuracy. 

Q.  Assuming,  Mr.  Alvord,  that  these  determinations  as 
made  by  Mr.  Randolph  give  the  mean  velocity  of  the  central 
portion  of  the  stream,  state  whether  or  not  in  your  opinion  cor- 
rections of  the  character  named  and  described  by  Mr. 

12863  Randolph  are  necessary? 

A.     1  believe  that  they  are  not  necessary. 

Q.  What,  then,  would  you  consider  the  length  of  time  that 
it  would  take  pollution  to  pass  over  the  described  distance  as 
the  results  of  these  experiments  so  conducted  by  Mr.  Randolph 
at  the  time  such  experiments  were  made? 

A.  I  should  judge  that  fifteen  days  actual  time  would  fairly 
represent  the  ability  of  the  water  of  the  Illinois  and  Desplaines 
rivers  to  carry  pollution  to  the  Chain  of  Rocks  at  the  stage  when 
the  experiments  were  made. 

Q.  State  whether  or  not  in  your  opinion  the  mean  flow  of 
the  stream  should  be  considered  as  the  time  element  in  the  pass- 
age of  sewage  and  pollution  from  a  given  point  to  a  point  below 
on  that  stream? 

A.     I  think  it  should  not.    Pollution  is  carried  much  faster 

on  a  given  stream  than  would  be  indicated  by  a  mean  average 

flow.    It  may  not  be  carried  as  fast  as  the  very  fastest  thread  of 

the  stream,  but  it  is  certainly  carried  as  fast  as  the  average 

velocity  of  the  central  or  fastest  part. 

12864  Q.     Have  you  examined  the  evidence  of  the  experiments 
conducted  by  Professor  Van  Ornum.  described  in  the 

records  of  this  case  .' 

A.     I  have. 

Q.  Taking  into  consideration  the  testimony  of  Mr.  Ran- 
dolph in  the  experiment  which  he  conducted  with  the  floats  in 
obtaining  the  velocity  of  the  water  in  the  Illinois  river,  in  July, 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        17 

1903,  I  will  ask  you  to  state  what  conclusions  you  draw  from  a 
comparison  of  the  respective  velocities  obtained  by  Mr.  Ran- 
dolph and  Professor  Van  Ornum,  and  taking  into  consideration 
the  evidence  as  to  the  guage  readings  that  existed  for  a  period 
prior  to  these  experiments  and  subsequent  thereto,  as  introduced 
in  evidence  by  Mr.  Randolph  and  Crane,  in  what  way  do  these 
experiments  represent  the  minimum  or  maximum  velocity  of  the 
water  in  the  Illinois  river! 

A.  I  should  judge,  in  answer  to  the  first  part  of  your  ques- 
tion, that  the  float  experiments  of  Mr.  Randolph  in  July  1903, 
were  undertaken  at  a  very  much  lower  stage  of  the  river  than 
were  those  of  Professor  Van  Ornum  in  March,  1903,  as  Pro- 
fessor Van  Ornum  finds  materially  greater  velocity  than  does 
Mr.  Randolph. 

I  also  observe  that  Professor  Van  Ornum  commenced  his 
float  experiments  in  a  low  stage  point,  between  two  March  rises, 
in  the  river.  There  were  flowing  over  the  Bear  Trap  dam  at. 
the  time  he  commenced  his  operations,  as  taken  from  the  figures 
in  the  tables  in  the  evidence,  289,000  cubic  feet  per  minute,  which 
gives  a  rather  low  velocity  in  the  drainage  channel.  About 
394,000  cubic  feet  per  minute  was  passing  over  dam  number  one 
at  Joliet  at  the  same  time. 

Eight  days  prior  to  this,  and  on  the  8th  and  9th  of  March, 
707,000  and  718,000  cubic  feet  per  minute,  respectively,  passed 

over  the  dam  at  Joliet. 

12866  Five  days  after  Professor  Van  Ornum  commenced  his 
experiments,  or  on  the  21st  and  22nd  of  March,  764,000 
and  711,000  cubic  feet  per  minute  passed  over  dam  number  one, 
or  nearly  double  the  amount  of  flow,  both  earlier  and  later,  was 
in  existence  than  occurred  when  his  experiments  were  com- 
menced. 

It  would  seem,  therefore,  that  Professor  Van  Ornum 's  ex- 
periments were  undertaken  at  a  very  comparatively  high  stage 
but  not  by  any  means  the  highest  stage  so  far  as  the  drainage 
channel  and  the  upper  portion  of  the  Desplaines  river  are  con- 
cerned. 

In  passing  Peoria,  Professor  Van  Ornum  observes  the  stage 
of  water  upon  the  gauge,  which  I  find,  by  referring  to  the  table 
of  flow  submitted  by  Mr.  Jacob  A.  Harmon,  in  this  case,  gives  a 


18  The  State  of  Missouri  vs. 

flow  of  about  50,000  cubic  feet  per  second.  This  flow  would  cor- 
respond to  a  stage  of  the  river  which  is  somewhat  overflowing 
the  banks  in  the  lower  courses. 

As  Professor  Ornum  used  submerged  floats,  I  feel  that  th3 

actual  time  traveled  by  the  velocity  floats  represents  fairly  the 

mean  velocity  of  the  pollution  vehicle,  and  I  take  the  total  time 

as  represented  by  these  floats  as  representing  the  total 

12867  time  which  it  requires  to  travel  the  total  distance  under 
consideration,  with  the  exception  that  I  believe  that  there 

are  times  when  the  velocity  in  the  drainage  channel  in  that  por- 
tion of  the  river  immediately  below  the  Bear  Trap  Dam  is 
greater  than  those  which  he  found. 

In  1898  I  was  engaged  as  consulting  engineer  for  the  State 
Board  of  Canal  Commissioners  in  litigation  with  the  sanitary 
district  of  Chicago  over  certain  water  powers  and  these  chan- 
nels below  the  Bear  Trap  Dam,  and  had  occasion  to  very  care- 
fully study  the  velocities  and  stages  and  various  stages  in  this 
vicinity.  I  have,  therefore,  verified  Professor  Van  Ornum 's  float 
experiments  in  this  vicinity,  recognizing  them  to  correspond 
with  what  I  know  to  be  the  facts  in  the  spring  rises  in  the  upper 
portion  of  the  course  under  consideration.  Below  Lake  Joliet 
I  have  accepted  Professor  Van  Ornum 's  experiments  to  the 
chain  of  rooks  as  being  properly  indicative  of  what  might  hap- 
pen in  ordinary  spring  floods. 

From  Bridgeport  to  the  chain  of  rocks  I  find  that  9.8  days 

is  consumed,  using  mean  velocity  to  Joliet,  and  Professor  Van 

Ornum 's  float  experiments  from  there  to  the  chain  of 

12868  rocks.     I  do  not  consider  that  this  is  the  shortest  time 
in  which  polution  would  travel  this  distance,  but  believe 

that  the  maximum  flood  such  as  occurred  in  1892  would  reduce 
this  time  to  at  least  eight  days  and  possibly  slightly  less.  The  9.8 
days  represents  to  my  mind  a  stage  which  could  be  counted  upon 
as  occurring  a  number  of  times  in  each  year. 

ME.  JEFFRIES:  Q.  State  whether  or  not  you  have  had 
occasion  to  examine  and  study  the  velocity  and  stages  of  the 
livers  in  question,  in  the  course  of  your  professional  career  ? 

A.  I  have. 

Q.  From  what  you  have  said  of  your  observations  of  the 
testimony  introduced  in  this  case  and  of  the  testimony  of  Mr. 
Randolph,  from  his  float  experiments,  state  whether  or  not  in 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        19 

your  opinion  the  float  experiments  of  Mr.  Randolph  represent 
a  mmuinum  velocity  of  the  water  in  the  Illinois  river  from 
Chicago  to  St.  Louis  at  all  times  of  the  year ! 

A.  Not  having  been  able  to  ascertain  the  specific  stage  at 
the  time  of  Mr.  Randolph's  experiments,  I  should  be  unable 
to  state  positively  that  his  experiment  was  made  at  the  minimum 
stage  of  the  river,  but  speaking  generally  it  is  my  impression  that 
it  was  arid  represents  the  average  of  the  minimum  velocity  in 
the  ordinary  dry  seasons  of  the  year  between  the  Chicago  river 
.and  the  chain  of  rocks. 

MR.  JEFFRIES :  Q.  I.  will  ask  you  if  you  have  ex- 
amined the  chart  referred  to  by  Mr.  Rudolph  Hering, 

12870  who  testified  for  respondents  in  this  case,  in  which  it 
is  referred  to  by  Mr.  Hering  in  his  evidence  as  follows, 

the  chart  with  the  caption  ''Sanitary  District  of  Chicago, 
schematic  representation  of  the  self-purification  of  the  waters 
of  the  Missouri,  Mississippi  and  Illinois  rivers  between  tho 
points  indicated  based  upon  the  longevity  of  the  life  of  the 
typhoid  bacillus  as  fixed  by  the  experiments  made  under  the 
direction  of  Hiram  F.  M  ills,  the  results  of  which  are  given  in  the 
paper  entitled  "Typhoid  fever  in  its  relation  to  water  supply T  " 

A.  I  have. 

Q.  State  what  to  you,  then,  it  represents,  as  observed  by 
you  as  a  hydraulic  sanitary  engineer? 

A.  It  represents  an  attempt  to  derive  the  possible  amount 
of  contamination  in  the  water  at  the  chain  of  rocks  from  the 
sanitary  district  of  Chicago,  by  assuming  that  the  original  pol- 
lution is  proportional  to  the  population,  and  that  the  longevity 
of  a  typhoid  bacillus  is,  as  found  by  the  experiments  of  Hiram 
F.  Mills  in  the  paper  referred  to.  The  chart  also  makes  the 
same  deductions  for  the  Mississippi  and  Missouri  rivers  and 
gives  the  rate  of  fall  of  the  three  watersheds.  In  the  case  of 
the  Illinois  river  the  length  of  time  of  flow  from  the  Chi- 

12871  cago  river  to  the  chain  of  rocks  is  taken  at  18%  days, 
as  stated  by  M.r.  Randolph  from  his  experiments,  after 

adding  to  the  original  experiments  an  additional  time  for  the 
correction  to  the  mean  velocity.  It  would  seem  to  me  in  the 
first  place  that  Mr.  Hering  has  not  given  due  weight  to  the  rela- 
tive effectiveness  of  different  populations  in  the  production  of 
typhoid  pollution.  The  sanitary  district  of  Chicago  has  been 


20  The  State  of  Missouri  vs. 

afflicted  for  years  with  an  abnormal  number  of  typhoid  deaths. 
Other  cities  on  the  Illinois  watershed,  deriving  their  water  sup- 
ply from  artesian  wells,  have  extremely  low  death  rates  from, 
the  same  cause.  It  would  appear,  therefore,  to  me,  that  to  make 
the  diagram  more  exact  some  method  should  be  introduced  by 
which  the  disparity  in  typhoid  data  could  be  allowed  for  in  its 
effect  upon  the  St.  Louis  water  supply. 

Again,  I  should  judge  that  the  diagram  as  compiled  under 

Mr.  Hering's  direction  gives  the  time  of  travel  of  the  pollution 

vehicle  at  low  stages  of  the  river  and  therefore  does  not 

12872    fairly  indicate  the  greater  danger  of  pollution  to  the  St. 

Louis  supply  at  medium  or  high  stages  of  the  river.    It 

would  seem  that  the  diagram  should  be  so  constructed  that  these 

modifications  might  be  clearly  apparent. 

Q.  Have  you  prepared  a  diagram  which,  according  to  the 
methods  suggested  by  Mr.  tiering,  based  upon  the  experiments 
of  Mr.  Hiram  F.  Mills,  which  would  also  include  the  two  modi- 
fications  just  described  by  you  ? 

A.     I  have. 

Q.     Will  you  submit  this  diagram  ? 

A.     I  will. 

ME,  JEFFRIES:  No'w,  Mr.  Commissioner,  I  offer  this 
chart  to  be  read  in  evidence  and  be  made  a  part  of  the  testimony 
of  this  witness. 

THE  COMMISSIONER:  The  chart  is  marked  complain- 
ant's rebuttal  chart  number  two  (2),  and  is  as  follows : 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        21 
12873  Complaints  Rebuttal  Chart  No.  2. 


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22  The  State  of  Missouri  vs. 

12874  ME.   JEFFRIES:      Q.     'Will  you  please  explain  this 
diagram  or  chart .' 

A.  The  diagram  which  I  have  submitted  covers  only  the 
reduction  of  the  typhoid  bacterial  pollution  in  the  Illinois  river 
as  being  the  object  under  consideration,  and  is  prepared  as 
nearly  as  possible  in  the  manner  described  by  Mr.  Crane  in  his 
testimony,  using  the  experiments  of  Mr.  Hiram  F.  Mills  as  to 
the  longevity  of  the  typhoid  germ.  The  ordinates  in  the  dia- 
gram represent  the  tributary  population  calculated  in  its  rela- 
tive typhoid  death  production.  As  a  basis  for  this  I  have  as- 
sumed a  standard  of  20  deaths  per  100,000  living  as  be:ng  the 
death  rate  of  an  ordinary  well  regulated  city  in  the  situation 
of  Chicago,  having  due  regard  to  the  protection  of  its  water 
supply. 

Upon  this  basis  I  have  determined  for  the  year  1902  the 
typhoid  death  rate  of  Chicago  and  the  cities  along  the 

12875  Illinois  river  which  are  given  in  the  table  in  the  lower 

left  hand  corner  of  the  diagram. 

This  diagram  shows  in  the  first  column  the  place  under 
consideration;  in  the  second  column  the  population  of  the  place 
from  the  estimated  Federal  census  of  1902,  when  possible.  The 
third  column  shows  the  typhoid  death  rate  in  1902  per  100,000 
living,  and  the  last  column  shows  the  tributary  population  con- 
tributing typhoid  contamination  on  the  basis  of  20  deaths  per 
100,000  living,  per  annum,  as  calculated  from  the  actual  popu- 
lation and  the  actual  typhoid  death  rate.  The  population  of  the 
sanitary  district  is  taken  from  Mr.  Hering's  chart  and  not  from 
the  Federal  census.  The  abscisse  of  the  diagram  give  the  num- 
ber of  days  consumed  in  the  flowing  of  the  pollution  from  the 
sewers  of  Chicago  to  the  15th  day,  based  upon  the  float  experi- 
ments of  Professor  Van  Ornum,  from  Lake  Joliet  to  the  chain 
of  rocks,  and  from  my  estimates  of  the  velocity  in  the  drainage 

canal,  and  Desplaines  river  down  to  Lake  Peoria. 

12876  With  this  data  I  have  plotted  a  curve  in  a  similar  man- 
ner to  that  plotted  upon  the  diagram  prepared  under  the 

direction  of  Mr.  Hering,  giving  due  consideration  to  the  per- 
centage of  reduction  in  the  typhoid  contamination  from  the 
population  center  through .  the  proper  increments  of  time  to 
agree  with  the  experiments  of  Hiram  F.  Mills. 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        23 

ME.  JEFFRIES:  Q.  State  what  the  curve  in  this  chart 
indicates! 

A.  The  curve  plotted  upon  the  diagram  indicates  the  rela- 
tive typhoid  bacterial  pollution,  so  far  as  the  same  can  be  predi- 
cated upon  the  population,  by  using  the  bacterial  reduction 
found  in  the  experiments  of  Hiram  F.  Mills  and  substantiated 
by  Dr.  Horrocks. 

ME.  JEFFRIES :    Q.    State  whether  or  not  as  a  general 

12877  proposition  the  number  of  deaths  from  typhoid  fever 
in  any  community  represent  the  total  amount  of  pollu- 
tion from  typhoid  bacteria! 

A.  They  do  not;  if  they  are  confined  to  deaths  only  they 
do  not  represent  the  whole  number  of  cases. 

ME.  JEFFEIES :  Q.  What  else  should  be  taken  into  con- 
sideration? 

A.  There  are  always  a  very  large  number  of  cases  of  ty- 
phoid fever  which  recover  and  which  nevertheless  are  active 
producers  of  typhoid  infection  in  addition  to  the  infection  pro- 
duced by  cases  when  deaths  have  occurred. 

Adjourned  until  May  26,  1904,  10:00  a.  m. 

12878  Eoom  282,  Southern  Hotel,  St.  Louis,  Mo.    10:00  a.  m., 
Thursday,  May  26,  1904.    Continuation  pursuant  to  ad- 
journment. 

Present,  the  Commissioner  and  same  counsel  representing 
the  respective  parties. 

JOHN  W.  ALVORD 

resumed  the  stand  for  further  direct  examination,  by  Mr.  Jef- 
fries, and  testified  as  follows : 

Q.  State  whether  or  not  this  diagram,  as  constructed, 
represents  pollution  from  fatal  cases  alone  or  from  all  cases 
which  actually  existed  in  the  communities  under  consideration, 
special  reference  being  here  made  to  complainant's  rebuttal 
chart  number  two  (2). 

A.     It  represents  the  .comparative  pollution  contributed  by 

the  fatal  cases  alone.     Furthermore  it  should  be  remembered 

that  fatal  cass  cease  to  contribute  infection  to  the  stream 

12879  on  and  after  the  date  of  the  death,  while  unfatal  cases 
do  and  may  continue  to  contribute  infecting  material  to 

the  stream  for  days,  weeks  and  even  months. 


24  The  State  of  Missouri  vs. 

The  diagram  as  constructed  fails  to  take  account  of  this 
extra  and  added  pollution  and  is  therefore  conservative. 

ME.  JEFFRIES:  Q.  How  do  the  corrections  which  you 
have  applied  to  Mr.  Hering's  chart  affect  the  final  results  and 
especially  the  estimate  of  the  typhoid  contributing  pollution  at 
the  chain  of  rocks? 

A.    Assuming  active  typhoid  contamination  is  proportional 
to  the  population,  and  assuming  diminution  in  the  number  of 
typhoid  germs  day  by  day  to  be  as  shown  in  the  experiments 
of  Mr.  Hiram  F.  Mills,  the  modifications  which  I  have  intro- 
duced in  the  diagram  would  considerably  increase  the 
12880     amount  of  typhoid  pollution  entering  the  intake  at  St. 
Louis. 

I  find  that  whereas  Mr.  Hering's  diagram  shows  that  the 
typhoid  pollution  entering  the  intake  at  the  chain  of  rocks  is 
equivalent  at  the  end  of  a  low  river  flow  of  18%  days  to  an 
infection  from  a  tributary  population  immediately  above  the 
intake  of  a  city  of  13,000  people,  the  conclusions  of  the  dia- 
gram would  seem  to  indicate  that  the  normal  flow  of  fifteen 
days  would  be  equivalent  to  an  infection  from  a  tributary  popu- 
lation with  a  death  rate  of  20  per  100,000  living  of  a  city  located 
immediately  above  the  intake,  with  a  population  of  about  90,000 
people,  while  on  the  basis  of  ordinary  spring  floods,  such  as 
were  gauged  by  Professor  Van  Ornum  the  infection  arising  at 
the  chain  of  rocks  would  be  equivalent  to  the  population  of  a 
city  of  415,000  population,  situated  immediately  above  the  in- 
take tower,  and  with  a  typhoid  death  rate  of  20  per  100,000. 

TVith  a  maximum  flood  such  as  occurs  only  once  in  every 
several  years,  it  w^ould  appear    that    the    comparative 
32881     pollution  reaching  the  intake  of  the  St.  Louis  water- 
works would  be  equivalent  to  a  population  of  960,000 
with  a  typhoid  fever  death  rate  of  20  per  100,000  living,  this 
latter  assumption  being  based  upon  the  movement  of  the  pol- 
lution vehicle  from  the  Chicago  river  to  the  chain  of  rocks  in 
eight  days. 

12882    MR.  JEFFRIES:     Q.    Why  do  you  employ  20  deaths 
from  typhoid  fever  per  100,000  population  in  your  last 
answer? 

A.  Because  there  are  a  very  considerable  number  of  cities 
which  have  so  exercised  care  and  discretion  in  the  protection 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        25 

of  their  water  supplies  that  they  have  reduced  the  typhoid  death 
rate  to  a  point  below  this  rate.  Some  of  the  smaller  cities  upon 
the  Illinois  river  have  typhoid  death  rates  as  low  as  6.9  per 
100,000  living.  It  would  therefore  seem  to  be  a  fairly  reason- 
able standard  to  assume  that  all  cities  having  reasonable  regard 
to  the  purity  of  their  water  supplies  should  be  able  in  the  light 
of  present  science  to  reduce  their  typhoid  death  rate  at  least  to 
the  basis  assumed,  if  not  materially  lower.. 

ME,  J  EFFEIES :    Q.    In  the  chart  which  you  have  intro- 
duced in  evidence  in  comparison  with  the  chart  or  diagram  in- 
troduced in  evidence  by  Mr.  Hering,  based  upon  the  experiment 
of  Hiram  F.  Miils,  what  weight  do  you  attach  to  these 
3 2883     experiments ! 

A.  I  believe  they  are  what  might  be  termed  incomplete 
investigations,  that  is  to  say,  they  are  valuable,  but  neither  suf- 
ficiently comprehensive  nor  numerous.  The  results  show  that 
typhoid  germs  do  live  under  the  conditions  of  the  experiments 
the  length  of  time  given,  but  they  do  not  show  that  typhoid 
germs  may  not  live  much  longer.  The  difficulty  of  isolating 
typhoid  bacteria  from  waters  of  known  pollution  would  seem  to 
substantiate  this  v\r?  <? 

12884     ME.  JEFFEIES:    Q.    Are  you  familiar  with  the  testi- 
mony of  Professor  Kinnicutt  in  this  case? 

A.     I  have  read  it  over. 

Q.  State  whether  or  not  you  are  familiar  with  the  princi- 
ples of  practice  of  modern  sewage  purification? 

A.     I  am. 

Q.  State  whether  or  not  you  have  given  attention  to  the 
development  of  processes  of  sewage  purification  by  means  of 
septic  tanks? 

A.  I  have  given  particular  attention  to  the  development 
of  septic  tanks  and  have  designed  some  ten  or  fifteen  plants  for 
municipalities  in  which  a  septic  tank  has  been  employed  on 
my  recommendations.  Of  these  plants  eight  septic  tanks  have 
been  constructed  under  my  immediate  supervision  for  different 
municipalities  and  have  been  in  operation  for  periods  ranging 
from  one  to  four  years.  Two  of  these  plants  have  been  under 
my  immediate  supervision  ever  since  construction  and  I  have 
watched  the  operation  of  others. 

Q.     What  is  septic  action  and  how  long  should  sewage 


26  The  State  of  Missouri  vs. 

12S85     remain  in  a  septic  tank  in  order  to  obtain  practical  re- 
sults from  a  sanitary  standpoint? 

A.  Septic  action  is  the  process  of  breaking  down  the  or- 
ganic matters  in  sewage  by  micro-organisms  or  their  products 
in  the  absence  of  oxygen.  This  process  is  continuously  brought 
about  by  allowing  the  sewage  to  come  nearly  or  quite  to  a  state 
of  rest  in  deep  tanks  and  allowing  it  to  remain  so  until  the  dis- 
solved oxygen  present,  if  any,  is  exhausted  and  until  the  solid 
particles  of  the  sewage  have  been  attacked  and  broken  up  more 
or  less  in  soluble  compounds.  It  is  desirable  in  order  to  pro- 
vide favorable  conditions  for  this  process  that  the  temperature 
remain  as  constant  as  possible  and  very  high,  and  it  is  prefer- 
able that  light  and  air  should  be  excluded,  although  this  is  not 
absolutely  essential.  The  proper  period  of  rest  necessary  to 
get  the  best  results  will  vary  with  the  composition  of  the  sewage, 
its  temperature  and  character.  It  has  been  found  desir- 

12886  able  to  adjust  the  rest  period  so  that  the  temperature  and 
other  variables  can  be  controlled  and  the  period  of  rest 

adapted  to  the  concentration  of  the  sewage  and  its  relative  flow, 
proportioned  to  the  tank  in  which  it  is  confined. 

ME,  JEFFBIES :  Q.  State  whether  or  not  flowing  sewage 
ordinarily  undergoes  the  process  of  septic  action'? 

A.     It  does  not  ordinarily. 

Q.  State  whether  or  not  diluted  sewage  flowing  in  open 
channels  simulate  septic  tank  conditions? 

A.  It  would  not.  The  flow  of  liquids  through  open  chan- 
nels tend  to  bring  all  portions  of  the  liquid  from  time  to  time  to 
the  surface  where  it  may  receive  oxidizing  influences  tending 
to  retard  septic  action. 

Q.  Are  you  acquainted  with  the  present  physical  condi- 
tion of  the  Chicago  Drainage  Canal? 

A.     I  am. 

Q.  Please  compare  the  conditions  existing  in  the  Chicago 
Drainage  Canal  with  those  of  a  true  septic  tank! 

12887  A.    In  the  Chicago  Drainage   Canal  we  have  a  large 
volume  of  diluted  sewage  flowing  at  the  rate  of  one  to 

three  feet  per  second,  giving  ample  opportunity  for  renewing 
its  dissolved  oxygen.  And  we  have  this  action  further  increased 
by  the  opportunity  of  the  wind  to  stir  the  surface  of  the  stream 
and  still  further  oxygenate  it. 


T/ie  £7a£e  o/  Illinois  and  the  Sanitary  District  of  Chicago.        27 

We  have  also  an  opportunity  for  exposure  to  low  tempera- 
tures, light,  etc.,  which  are  detrimental  to  the  septic  action. 

Q.  State  whether  or  not  septic  action  to  any  considerable 
extent  takes  place  in  the  sewage  of  Chicago  during  its  passage 
through  the  drainage  canal! 

A.     It  does  not. 

Q.  Are  you  acquainted  with  the  chemical  data  that  has 
been  introduced  in  evidence  by  the  defendants? 

A.     I  am  to  some  extent. 

Q.  State  whether  or  not  in  your  opinion  the  chemical  data 
introduced  by  the  defendants  with  reference  to  the  character  of 
the  contents  of  the  Chicago  drainage  canal,  indicate  any  septic 
action  has  taken  place? 

12888  A.     My  opinion  is  that  they  do  not.     The  amount  of 
improvement  in  the  sewage  in  its  travel  of  the  drainage 

canal  found  by  Professor  Kinnicutt  in  his  testimony  in  this  case 
would  seem  to  me  to  be  largely  due  to  aerobic  action.  Possibly 
there  is  anaerobic  action  to  a  very  limited  extent,  but  not  enough 
in  my  opinion  to  influence  the  results  perceptibly. 

Q.  State  whether  or  not  the  extensive  dilution  of  the  sew- 
age of  the  city  of  Chicago  by  the  richly  oxygenated  water  of 
Lake  Michigan  is  a  useful  preliminary  to  septic  action? 

A.  It  is  not.  On  the  contrary  it  is  distinctly  opposed  to 
the  inception  of  septic  action.  In  good  practice,  in  the  design- 
ing of  septic  tanks  it  is  the  endeavor  always  to  bring  the  sewage 
into  the  tank  as  quietly  as  possible,  undiluted  with  surface  or 
underground  waters  containing  dissolved  oxygen. 

Q.  State  whether  or  not  you  were  familiar  with  the  South 
branch  of  the  Chicago  river  prior  to  the  opening  of  the  drainage 
canal  ? 

A.    I  am. 

Q.  What  was  the  condition  of  that  part  of  the  river  at 
that  time? 

A.  It  presented  all  the  characteristics  of  septic  action  to  a 
marked  degree. 

12889  Q.     What  were  those  characteristics? 

A.  The  absence  of  marked  current,  and  the  presence  in 
certain  places  of  foul  products  and  considerable  surface  scum, 
the  absence  of  undissolved  oxygen  as  shown  by  chemical 
examinations  and  the  visible  production  of  gases  bubbling  up 


28  The  State  of  Missouri  vs. 

from  the  depths  below  such  as  characterize  the  septic  tank  when 
in  active  reduction  of  its  organic  matter. 

MR.  JEFFRIES:     Q.     State  whether  or  not  in  your  opin- 
ion typhoid  germs  are  now  more  able  to  survive  longer  under  the? 
present  condition  of  sewage  dilution  in  the  drainage 

12890  canal  than  they  could  formerly  have    survived   in   the 
South  Branch  of  the  Chicago  River  or  in  the  Illinois  and 

Michigan  Canal! 

A.  I  believe  that  typhoid  germs  could  survive  materially 
longer  under  the  present  conditions  than  was  the  case  formerly 
in  the  Illinois  and  Michigan  Canal  and  the  South  Branch  of  the 
Chicago  River. 

Mr.  Jeffries:  Q.  Taking  into  consideration  your  knowl- 
edge of  septic  operation,  and  all  that  you  know  upon  the  sub- 
ject of  sanitary  science  and  sanitary  hydraulic  engineering  and 
taking  into  consideration  the  physical  condition  of  the  Illinois 
River  the  drainage  canal  and  the  Desplaines  River,  and  the 
chlart  or  diagram  introduced  in  evidence  by  Mr.  Hering,  and 
the  diagram  introduced  in  evidence  by  you  in  connection  there- 
with, state  whether  or  not  in  your  opinion  the  presence 

12891  of  sewage  from  the  sanitary  district  of  Chicago  in  the 
waters  of  the  Mississippi  River  at  the  chain  of  rocks 

makes  it  more  costly  to  provide  suitable  water  for  domestic 
purposes  for  the  citizens  of  St.  Louis  ? 

A.     In  my  opinion  it  does  make  it  more  costly. 

Mr.  Jeffries:  Q.  In  what  respects  is  the  water  supply  of 
St.  Louis  made  more  costly  or  difficult  by  virtue  of  the  opening 
of  the  drainage  canaj? 

A.  The  design  and  construction  of  a  purification  plant  deal- 
ing with  a  seriously  polluted  water,  especially  of  one  of  known 
high  typhoid  pollution  should  be  more  complete  and  delicately 
adjusted  to  its  work  than  when  dealing  only  with  water 

12892  of  rare  infection  and  presenting  less  dangerous  difficul- 
ties such  as  turbidity  and  color. 

Mr.  Jeffries:  Q.  What  form  should  this  added  protection 
take? 

A.  It  should  take  the  form  either  of  double  filtration  or 
have  complete  sedimentation  in  more  than  one  stage  followed 
l>y  most  careful  filtration. 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        29 

Mr.  Jeffries:  Q.  State  whether  or  not  you  know  of  any 
case  where  double  nitration  is  being  used  or  resorted  to! 

A:  It  has  been  resorted  to  in  several  places  in  Germany 
12893  and  has  been  recommended  at  Springfield,  Massachu- 
setts, by  Messrs.  George  W.  Fuller  and  Samuel  M.  Gray,. 
and  is  now  being  introduced  into  the  new  filtration  plant  of 
Philadelphia  by  Mr.  John  W.  Hill,  in  which  case  they  are  pro- 
posing to  pass  water  of  known  typhoid  pollution  through  what 
are  called  preliminary  filters  as  a  first  stage  and  then  through 
slow  sand  filters  as  -a  second  stage. 

Mr.  Jeffries:  Q.  Would  such  methods  be  more  expensive 
than  single  filtration  f 

A.  They  would.  It  is  my  opinion1  that  they  would  very 
greatly  increase  the  cost  of  filtration,  both  in  its  first  construc- 
tion and  in  operation.  % 

Mr.  Jeffries:     Q.     State  whether  or  not  single  sand  filtra- 
tion as  practiced  in  the  United  States  is  always  a  protection 
from  the  danger  of  typhoid  infection ! 

A.     It  is  not. 

Mr.  Jeffries:     Q.     Why  is  it  not? 

A.  Sand  filtration  of  either  type  is  practically  able  to  re- 
move pathogenic  bacteria  from  domestic  water  supply,  but  we 
find  that  in  practice  filtration  works  are  a  most  delicate  mechan- 
ism, which  have  to  be  very  carefully  operated  in  order  to  pro- 
duce at  all  times  and  under  all  conditions  the  results  antici- 
pated by  their  designers.  In  cases  where  the  danger  of  infec- 
tion hovers  over  the  filtration  plant  year  in  and  year  out  it  is. 
obvious  that  the  slightest  relaxation  may  result  in  the  most 
serious  consequences. 

Mr.  Jeffries :     Q.     State  whether  or  not  you  know  from  your 
own  observations  and  study  of  the  cases  in  which  single  sand 
filtration  or  filter  plants  of  either  type  have  failed  to 
12895    protect  the  water  supplies  from  typhoid  infection? 

A.  I  do.  There  have  come  under  my  observation,  typhoid 
epidemics  in  water  supplies  protected  by  filtration  in  the  follow- 
ing places: 

Eock  Island,  Illinois, 

Ashland,  Wisconsin, 

Berlin,  Germany, 


30  The  State  of  Missouri  vs. 

Lawrence,  Massachusetts, 
Lake  Forest,  Illinois, 
Butler,  Pennsylvania, 
Waterloo,  Iowa, 

Beaver  Fajls,  Pennsylvania,  and 
Augusta,  Maine. 

MR.  JEFFRIES    Q.     Mr.  Alvord,  are  you  a  member  of  any 
engineering  societies'  or  associations? 

A.     Yes,  sir;  I  am  a  member  of  the  American  Society 

12896  of    Civil    Engineers  since  1893.     I  am  a  member  and 
trustee  of  the  Western  Society  of  Civil  Engineers.    I  am 

president  of  the  Illinois  Society  of  Civil  Engineers  and  Sur- 
veyors. I  am  a  member  of  the  American  Waterworks  Associa- 
tion and  of  the  New  England  Waterworks  Association.  I  am 
also  a  member  of  the  American  Public  Health  Association,  and 
am  serving  this  year  upon  its  committee  of  water  and  sewage 
purification.  1  am  a  member  of  the  American  Society  of 
Municipal  Improvements,  the  American  Academy  of  Social  and 
Political  Science,  and  of  the  Engineers7  Club  of  Chicago. 

Q.  Mr.  Bering,  who  testified  for  the  defendants  on  March 
10th  last,  was  asked  by  counsel  for  the  defendants  the  following 
question  "From  what  you  know  of  the  question  of  disposal 
of  sewage  and  from  the  knowledge  which  you  have  in  regard  to 
the  drainage  canal,  the  manner  in  which  it  is  operated,  and  tak- 
ing into  consideration  the  experience  you  have  had  since  you 
made  your  preliminary  report,  what  changes  would  you  recom- 
mend for  the  sewage  disposal  of  the  city  of  Chicago  if  the  same 
problem  was  submitted  to  you  now  which  was  submitted  to  you 
in  1886,  as  a  sanitary  and  hydraulic  engineer?"  An- 

12897  swering  this  question  Mr.  Hering  said  that  in  consider- 
ing the  several  ways  of  disposing  of  the  sewage  of  Chi- 
cago, from  personal  knowledge  and  experience,  my  recomenda- 
tion  would  be  that  the  sewage  of  Chicago  should  be  disposed  of 
by  dilution  through  the  channel  substantially  as  that  which  has 
been  constructed  with  the  subsequent  discharge  into  the  Des- 
plaines  and  Illinois  rivers."     Thereupon  the  following  further 
question  was  asked  him:    "In  the  study  of  this  problem  have 
you  discovered  anything  that  would  change  the  view  expressed 
by  you  in  your  preliminary  report  at  that  time?"    In  answer  to 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        31 

which  question  Mr.  Hering  said:  ;'I  have  not."  I  will  ask  you, 
Mr.  Alvord,  to  state  whether  or  not  there  are  in  y.our  opinion 
any  practical  modifications  of  the  existing  system  of  sewage  dis- 
posal of  the  city  of  Chicago  by  which  the  drainage  canal  could 
still  be  employed  for  keeping  the  Chicago  river  in  an  inoffensive 
condition  and  yet  avoid  the  pouring  of  unpurified  sewage  into 
and  through  the  canal  over  the  Bear  Trap  Dam  a,t  Lockport 
and  into  the  Desplaines  and  Illinois  rivers? 

A.  I  am  of  the  opinion  that  it  is  entirely  practicable  to 
retain  the  drainage  channel  so  that  it  can  be  still  employed  for 
keeping  the  Chicago  River  in  condition  and  yet  avoid  pouring 
unpurified  sewage  into  and  through  the  canal  and  into  the  Des- 
plaines and  Illinois  Rivers,  and  I  would  suggest  as  the  proper 
remedy  the  construction  of  suitable  intercepting  sewers  along 
the  Chicago  River  'and  its  branches,  by  means  of  which  the 
sewage  flow  of  the  city  may  be  kept  out  of  the  Chicago  River 
and  led  along  its  banks  to  the  upper  end  of  the  drainage  chan- 
nel beyond  Bridgeport  and  then  raised  by  a.  suitable  pumping 
station  preferably  operated  with  water  power  derived  from  the 
drainage  canal  to  and  into  a  suitable  purification  plant  con- 
structed in  accordance  with  the  latest  bacteriological 

12899  principles  and  effectually  remove  from  such  sewage  all 
or  practically  all  of  its  organic  wastes  and  pathogenic 

bacteria  and  emptying  the  effluent  from  such  sewage  plant  into 
the  drainage  channel  near  Bridgeport  to  be  conveyed  through 
the  same  and  through  the  Desplaines  and  the  Illinois  Rivers  in 
a  harmless  and  purified  state. 

Mr. 4 Jeffries:  Q.  State  whether  or  not  you  have  consid- 
ered the  relative  expense  of  such  a  plant  as  you  have  described 
in  your  last  answer! 

A.  I  have  considered  the  expense  in  a  general  way  and  am 
of  the  opinion  that  such  intercepting  sewers  .and  purification 
plant  could  be  constructed  at  an  expense  no  greater  than  that 
necessary  to  widen  the  South  Branch  of  the  Chicago  River  in 
order  to  increase  its  flow  of  dilution  water  to  the  requirements 
of  dilution. 

And  I  am  further  of  the  opinion  that  the  operating  ex- 

12900  pense  of  such  a  plant  would  be  no  greater  than  the  ope- 
rating expense  of  the  present  system  of  pumping  sewage 


32  The  State  cf  Missouri  vs. 

and  the  necessary  dilution  water  through  the  same  for  the  north- 
erly and  southerly  portions  of  the  sanitary  district  and  the  dilu- 
tion water  for  the  proposed  additions  to  such  sanitary  district. 

CROSS-EXAMINATION,  by  Mr.  Todd: 

Q.  In  figuring  out  such  a  purification  plant  as  you  have 
referred  to  in  your  last  answer  and  the  building  of  intercept- 
ing sewers  and  the  operation  of  pumps  and  the  installation  oi" 
pumping  machinery,  what  estimate  in  dollars  and  cents  do  you 
place  that  such  a  plant  would  cost,  according  to  your  esti- 
mates? 

A.     Between  twelve  and  fifteen  millions  of  dollars. 

Q.  Does  that  contemplate  the  purification  of  the  entire 
sewage  of  the  sanitary  district! 

A.     It  does. 

Q.  From  Calumet  on  the  south  and  Lake  View  on  the 
12901  north  and  the  building  of  intercepting  sewers  on  each 
side  of  the  Chicago  River  and  on  each  side  of  the  north 
branch  which  receives  the  sewage  from  its  adjacent  neighbor- 
hoods as  well  as  the  sewage  from  Twelfth  Street  south  and  the 
west  side? 

A.  I  should  not  think  it  necessary  to  build  intercepting 
sewers  on  each  side  of  the  river.  One  main  sewer  connecting 
across  the  river  by  tunnels  would  probably  result  in  economy 
of  expenditure  over  a  double  intercepting  sewer  along  each 
bank. 

Q.  How  would  you  intercept  the  sewers  that  empty  into 
the  Chicago  River  from  its  left  bank? 

A.  I  should  carry  an  intercepting  sewer  along  either  one 
or  the  other  banks  of  the  river,  along  the  most  economical  loca- 
tion, connecting  it  with  the  mouths  of  the  sewers  on  each  side 
of  the  river,  either  by  short  branch  tunnels',  grouping  several 
sewers  together  on  the  opposite  side  or  in  the  case  of  the  large 
sewers  by  direct  tunnel  connections  in  each  case. 

Q.  What  would  be  the  cost  that  you  would  figure  for  the 
pumps  necessary  to  pump  the  entire  sewage  of  Chicage  from  its 
sewers  and  the  intercepting  sewers  to  this  purification  plant! 

A.     I  would  not  be  able  to  give  you  those  detail  figures  at 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.         3o 

this  time  as  1  do  not  have  them  by  me.     The  estimates  were 

made  some  years  ago. 

12902     Q.    How  many  acres  of  land  would  be  necessary  for  the 
plant  located  in  the  neighborhood  of  Bridgeport,  suffi- 
cient to  dispose  of  the  entire  sewage  of  the  city  of  Chicago  and 
the  sanitary  district  ? 

A.  That  would  depend  entirely  upon  which  of  several 
available  systems  of  bacterial  purification  might  be  adopted. 

Q.  Taking  the  one  that  you  had  in  mind  when  you  gave 
your  testimony! 

A.     I  do  not  think  I  had  any  particular  one  in  mind. 

Q.  How  were  you  able  to  make  an  estimate  if  you  did  not 
have  a  particular  system  in  mind  upon  which  to  base  an  esti- 
mate I 

A.  By  estimating  the  cost  of  the  one  which  would  in  all 
probability  be  the  most  expensive. 

Q.  Taking  the  one  that  would  probably  be  the  most  ex- 
pensive, how  many  acres  of  land  in  the  neighborhood  of  Bridge- 
port would  it  require  to  establish  such  a  purification  plant? 

A.     Possibly  1,000  acres. 

Q.     Do  you  know  what  the  value  of  real  estate  in  the  neigh- 
borhood of  Bridgeport  is! 
1290o     A.     I  have  general  ideas. 

Q.  What  are  your  ideas  on  the  value  of  1,000  acres  of 
land  in  the  neighborhood  of  Bridgeport  where  you  contemplated 
the  establishment  of  such  a  plant,  per  acre? 

A.  Possibly  a  half  a  million  of  dollars.  It  would  be  desir- 
able perhaps  to  place  the  plant  at  the  point  where  the  maximum 
of  land  could  be  obtained  at  the  minimum  price,  not  confining 
ourselves  to  any  exact  location  in  the  vicinity  or  below  Bridge- 
port. 

Q.  Have  you  any  spot  in  mind  where  such  an  amount  of 
land  could  be  had  near  Bridgeport  at  $500.00  per  acre? 

A.  The  sanitary  district  of  Chic'ago  has  a  large  amount 
of  land  in  that  vicinity  and  without  having  given  the  subject 
particular  attention  I  should  judge  that  it  might  be  possible 
that  they  had  land  enough  without  having  to  purchase  any  ad- 
ditional. 


34  The  State  of  Missouri  vs. 

Q.  Do  you  assert  that  as  a  fact  or  as  a  surmise  thlat  tha 
sanitary  district  owns  1,000  acres  of  laud  within  a  distance  of 
three  or  four  miles  of  Bridgeport,  available  for  such  use? 

A.  I  would  not  limit  myself  to  three  or  four  miles.  It  is 
not  necessary  in  the  location  of  such  a  plant  to  limit 

12904  yourself.     The  plant  could  be  eight  or  ten  miles  away. 
Q.     If  the  sanitary  district  of  Chicago  owns  400  feet  on 

each  side  of  the  channel  from  its  mouth  at  Robey  Street  to 
Summit,  with  the  exception  of  a  few  places  where  it  goes  back 
as  far  as  700  or  800  feet,  would  you  consider  the  plant  such  as 
you  have  contemplated  could  be  utilized  on  a  long  stretch  of 
that  kind? 

A.  It  might  be  done  or  some  other  mode  of  purification 
which  occupied  less  land  thlan  that,  which  I  have  estimated 
anight  be  put  in.  There  are  several  different  kinds  of  bacterio- 
logical purification  which  demand  different  and  varying  amounts 
of  land.  We  find  at  times  we  are  limited  in  land  and  we  recom- 
mend often  that  kind  of  purification  which  can  be  placed  upon 
the  minimum  of  land.  If  we  find  that  land  of  a  suitable  char- 
acter exists  in  abundance  it  varies  our  ideas  as  to  what  form 
of  purification  we  wrould  recommend. 

Q.  In  bringing  the  sewage  from  the  different  sections  of 
the  city  what  estimate  did  you  place  upon  the  cost  of  the  con- 
struction of  additional  sewers  in  order  to  bring  the  sewage  to 
the  plant? 

12905  A.     About  five  million  dollars. 

Q.     Where  would  those  sewers  be  located? 

A.  Following  as  closely  as  possible  the  north  and  south 
branches  of  the  Chicago  river  and  endeavoring  to  strike  with 
the  shortest  possible  length  the  greatest  number  of  present  sew- 
er outlets  emptying  into  the  river. 

Q.  Have  you  figured  out  the  cost  of  such  a  system  as  you 
have  in  mind  in  making  your  estimate? 

A.  I  have  figured  it  far  enough  to  see  that  it  is  practicable 
and  reasonably  economical. 

Q.  Will  you  give  in  detail  briefly  the  plan  which  you  have 
in  mind  for  the  disposal  of  Chicago  sewage? 

A.  Well,  I  have  quite  a  number  of  plans  in  mind.  I  have 
not  limited  myself  to  any  one  plan. 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        o'j 

Q.  \Vell,  give  me  the  plan  as  it  pertains  to  the  delivery  of 
sewage  to  the  plant  which  you  had  in  mind? 

A.  Well,  in  order  to  utilize  as  far  as  possible  construction 
already  commenced,  I  would  begin  by  saying  that  the  intercep- 
ting sewers  now  under  way  would  form  possibly  a  basis  for  con- 
ducting the  sewage  of  the  outlying  portions  of  the  city 

12906  from  the  north  end  and  from  the  south  districts  so  far 
as  they  go.     These  I  should  supplement  with  additional 

intercepting  sewers  conveying  their  contents  and  the  outflow  of 
the  sewers  now  emptying  into  the  different  branches  of  the  river 
to  the  vicinity  of  the  drainage  channel  beyond  Bridgeport,  neces- 
sarily finding  that  in  doing  so  I  had  consumed  some  gradient 
or  fall  which  must  be  recovered  by  pumping  not  only  to  raise 
the  sewage  to  the  level  of  the  drainage  channel,  but  to  raise  it 
an  additional  height  necessary  to  pass  it  through  that  system 
of  purification  that  might  be  selected.  Different  systems  of 
purification  also  vary  in  that  they  require  different  amounts 
of  head  necessary  to  properly  purify  the  sewage  which  passes 
through  them. 

Q.  How  would  you  bring  the  sewage  from  the  north  branch 
of  the  city  to  Bridgeport? 

A.  The  north  side  of  the  city  has  already  under  construc- 
tion a  system  of  intercepting  sewers  along  the  lake  shore  now 
completed,  and  a  branch  across  at  Lawrence  Avenue  to  the  north 
branch  of  the  Chicago  river  where  it  is  proposed  to  erect  a 
pumping  station  to  elevate  that  sewage  into  the  north  branch. 
This  collects  all  of  the  sewage  of  the  north  portion  of  the  city, 
which  formerly  emptied  into  the  lake.  I  would,  there- 

12907  fore  begin  at  the  point  where  this  sewage  is  to  be  lifted 
into  the  north  branch  and  continue  a  new  intercepting 

sewer  from  that  point  along  the  north  branch  of  the  Chicago 
River  on  the  side  which  might  be  found  by  detailed  study  to 
be  the  most  convenient,  thence  to  the  junction  of  the  north 
branch  with  the  south  branch  of  the  Chicago  River  and  along 
the  south  branch  of  the  Chicago  River  to  Bridgeport,  in  such 
location  that  it  would  receive  the  discharge  of  all  of  the  sewers 
on  the  north  side  of  the  city  not  connected  with  the  intercepting 
sewer  system  now  under  construction,  it  would  be  further  neces- 
sary in  order  to  collect  the  sewage  of  the  north  side  of  the  city 


o 


6  The  State  of  Missouri  vs. 

to  extend  a  short  branch  of  the  intercepting  sewer  easterly  from 
the  junction  of  the  north  and  south  branches  of  the  Chicago 
River  to  intercept  those  sewers  emptying  into  the  main  river 
from  the  north  side. 

Q.  How  would  you  bring  the  Calumet  District  to  Bridge- 
port! 

A.     The  Calumet  district  within  the  limits  of  the  sanitary 

district  is  now  proposed  to  be  brought  to  the  east  fork  of  the 

south  branch  by  a  system  of  intercepting  sewers  now  ne'arly 

completed.     This  intercepting  system  contemplates  a  pumping 

station  in  the  vicinity  of  Seventy-third  Street,  I  thinkr 

12908  proposals  for  which  have  just  recently  been  advertised. 
This  pumping  station  will  lift  the  sewage  of  the  extreme 

southern  portion  of  the  district  into  the  intercepting  sewer  al- 
ready finished  or  nearly  so  which  runs  northerly  along  Stpney 
Island  Avenue  and  the  right  of  way  of  the  Illinois  Central  Rail- 
road to  Thirty-ninth  Street,  where  a  very  large  pumping  station 
is  now  being  erected  to  pump  dilution  water  into  a  conduit 
which  will  take  such  dilution  water  and  sewage  from  the  inter- 
cepting sewer  and  carry  it  westerly  to  what  is  known  as  the 
Stock  Yards  Slip  at  Halstead  Street. 

Q.  How  would  you  take  the  sewage  from  South  Chicago 
by  the  method  you  have  described  as  the  method  adopted  for 
the  Calumet  District? 

A.  The  sewage  of  South  Chicago  is  proposed  by  the  pres- 
ent plans  of  the  sanitary  district  of  Chicago  to  be  carried  to 
the  main  channel  by  way  of  Blue  Island  and  the  Sag  Valley.  I 
would  say  that  in  making  my  estimate  of  $5,000,000.00  for  in- 
tercepting sewers  I  covered  the  territory  of  the  original  sani- 
tary district  and  not  the  district  as  enlarged  by  the  act  of  the 
Legislature  in  1903.  Such  outlying  territories  as  have  since 
been  added  could  be  brought  to  Bridgeport  in  any  event  by 
methods  and  at  an  expense  which  would  be  equal  in 

12909  either  case  with  the  methods  and  within  the  costs  now 
proposed  by  the  sanitary  trustees,  but  the  preference, 

if  any,  in  favor  of  the  system  which  I  have  outlined  in  that 
no  dilution  water  would  have  to  be  pumped  in  addition  to  the 
sewage. 

Q.     What  estimate  do  you  place  for  the  widening  and  deep- 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        37 

ening  of  the  Chicago  River  to  a  width  of  200  feet  and  to  a  depth 
of  26  feet,  as  is  contemplated  to  be  done  at  present? 

A.  The  best  of  my  knowledge  and  belief  the  estimates  for 
widening  of  the  Chicago  River  to  the  uniform  width  of  200  feet 
so  far  as  I  have  seen  them  published  range  from  eleven  to 
fourteen  million  of  dollars.  I  believe  it  would  be  fair  to  say 
that  the  cost  can  not  be  accurately  estimated  in  advance  as  large 
portions  of  valuable  land  will  have  to  be  acquired  by  condemna- 
tion. 

Q.  Are  you  aware  of  the  amount  of  land  that  has  already 
been  acquired  by  condemnation  I 

A.     I  am  aware  that  condemnation  is  constantly  going  on. 

Q.  Are  you  aware  that  over  seven-tenths  of  the  land  has 
already  been  acquired! 

A.  I  have  no  information  other  than  that  that  I  have 
stated. 

Q.    And  this  is  in  detail  the  method  of  the  sewage  disposal 

systems  that  you  have  proposed  to  construct,  the  amount  of 

land  that  it  would  be  necessary  to  acquire  under  this 

12910    estimate  is  in  the  neighborhood  of  twelve  million  dollars? 

A.     The  total  co-st  of  the  whole  project  would  be  twelve 

to  fourteen  millions  of  dollars. 

Q.  At  the  time  that  Mr.  Hering  made  the  preliminary  re- 
port when  the  question  of  sewage  disposal  for  Chicago  was  un- 
der consideration  was  the  question  of  bacteriology  then  recog- 
nized as  a  science? 

A.     Not  generally. 

Q.  Was  the  question  of  the  purification  of  sewage  in  the 
manner  that  you  have  described  it  then  known? 

A.  The  purification  of  sewage  was  then  known  and  ex- 
tensively practiced,  but  the  systems  which  I  now  have  in  mind 
were  not  developed,  and  speaking  generally  the  systems  than 
in  use  while  efficient,  were  expensive. 

Q.  What  experiments  have  you  conducted  upon  the  lon- 
gevity of  the  typhoid  germ  as  a  bacteriologist? 

A.     None  whatever. 

Q.    Have  you  ever  separated  the  typhoid  germ  in  the  labo- 
ratory from  the  excreta  of  typhoid  patients? 
A.    I  have  not. 


38  The  State  of  Missouri  us. 

12911  Q.     Are  you  sufficient  of  a  bacteriologist  to  do  so? 
A.     I  am  not. 

Q.  Have  you  ever  made  any  experiments  of  your  own  upon 
the  longevity  of  the  typhoid  germ  in  sewage! 

A.     I  have  not. 

Q.  Have  you  made  any  experiments  of  your  own  upon  the 
longevity  of  the  typhoid  fever  germs  in  sterilized  water  in 
lake  water,  in  the  water  of  the  drainage  canal  or  the  waters  of 
the  Illinois  River? 

A.     I  have  not. 

Q.  Have  you  examined  and  read  the  experiments  intro- 
duced in  evidence  in  this  case  and  made  by  Professors  Jordan, 
Zeit  and  Russell? 

A.     I  have. 

Q.  Have  you  read  the  entire  testimony  in  regard  to  those 
experiments  or  has  it  been  told  to  you! 

A.  I  can  not  say  that  I  have  read  it  all.  My  time  has  been 
too  limited  to  read  all  that  has  been  introduced  on  the  sub- 
ject. I  have  read  portions  of  it  and  ana  familiar  with  parts 
of  it. 

12912  Q.     Have  you  read  the  experiments  of  Professors  Jor- 
dan, Zeit  and  Eussell  as  carefully  as  you  read  the  ex- 
periments of  Hiram  F.  Mills! 

A.     Yes  sir. 

Q.  In  reading  the  experiment  of  Hiram  F.  Mills,  have  you 
read  the  technique  of  the  manner  in  which  the  experiment  was- 
conducted  and  the  method  employed  in  the  detection  of  the 
typhoid  germ? 

A.     Yes  sir. 

Q.  How  do  the  methods  employed  by  Hiram  F.  Mills  com- 
pare with  the  methods  employed  by  Jordan,  Zeit  and  Russell  in 
the  detection  of  the  typhoid  germ? 

A.  I  should  not  consider  myself  competent  to  criticize  the 
technique  of  either  Mr.  Hiram  F.  Mills  or  Messrs.  Jordan,  Zeit 
and  Russell. 

Q.     Have  you  read  the  experiments  made  and  introduced 

in  evidence  in  this  case  in  the  testimony  of  John  W.  Hill  of 

Philadelphia,  who  is  in  charge  of  the  filtration  bureau? 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.  •      39 

12913  A.     1  have  rHad  as  much  of  it  as  was  possible  in  the  time 
at  my  disposal. 

Cv).  1  mean  the  testimony  on  the  experiment  of  the  typhoid 
germ  in  the  water  of  the  Schuylkill  River! 

A.  I  do  not  think  I  have  read  that.  I  do  not  remember 
TO  have  seen  that. 

Q.  In  the  chart  which  you  have  introduced  in  evidence, 
in  which  you  testified  that  since  the  opening  of  the  drainage 
canal  the  typhoid  rate  in  the  cities  on  the  watershed  of  the  Illi- 
nois River  has  gone  up  since  1899  to  1900,  exclusive  of  Chicago, 
1  believe  you  called  special  attention  to  that  feature  of  the- 
chart  in  your  direct  testimony  did  you  not! 

A.  It  seemed  to  me  a  variation  in  the  general  result  worth 
noticing. 

Q.  How  do  you  account  for  that  rise  as  evidenced  on  that 
chart  from  1899  to  1900! 

12914  A.     I  have  not  attempted  to    account  for    it    particu- 
larly.    I  think  I  observed  that  the  line  was  fairly  uni- 
form and  that  the  only  marked  departure  from  the  uniformity 
was  that  rise  which  I  considered  not  of  large  amount. 

Q.  For  the  years  1900,  1901  to  1902  there  is  a  fall  in  the 
typhoid  along  the  Illinois  River,  exclusive  of  Chicago,  is  there 
not,  as  evidenced  by  this  chart! 

A.     There  is  a  slight  fall. 

Q.     How  do  you  account  for  that? 

A.     I  have  not  attempted  to  account  for  it. 

Q.  Upon  the  Mississippi  River  from  1899  to  1901  there  is 
a  rise  in  the  typhoid  rate  as  evidenced  by  the  chart.  How  do 
you  account  for  that? 

A.  I  have  not  attempted  to  account  for  that,  or  for  any  of 
the  minor  fluctuations  except  on  the  theory  that  there  are  always 
fluctuations  in  any  such  death  rate,  and  that  in  order  to  be  of 
interest  they  should  be  somewhat  marked. 

Q.  There  was  a  rise  in  St.  Louis  from  1898  to  1899  to  1900 
—was  that  not  evidenced  by  this  chart? 

A.  That  was  on  the  face  of  the  returns  from  the  typhoid 
deaths. 

12915  Q.    From  the  face  of  the  returns  in  each  instance  is  it  not? 
A.    In  each  instance  with  the  exception  noted  in  the  lower 


40  The  State  of  M'u-nsuiiri  vs. 

right  hand  corner  of  the  chart  which  refers  to  a  dotted  line 
leaving  the  deaths  in  St.  Louis  at  the  year  1898  and  rejoining 
that  again  in  the  year  1901.  In  this  case  the  face  of  the  re- 
turns are  plotted  in  the  usual  line  in  which  all  of  the  St.  Louis 
deaths  are  situated,  and  the  possible  deduction  due  to  localized 
epidemics  is  shown  by  this  dotted  line  above  referred  to.  With 
that  exception  the  diagram  is  constructed  wholly  from  the 
deaths  agreed  upon  in  this  case. 

Q.  Is  there  anything  on  this  chart  that  shows  that  the  rise 
of  typhoid  fever  in  the  city  of  St.  Louis  is  due  to  the  typhoid 
condition  in  the  city  of  Chicago? 

A.     I  think  there  is. 

Q.  Will  you  point  out  on  this  chart  where  such  a  fact  ap- 
pears 1 

A.  The  diagram  shows  that  the  deaths  on  each  of  the  three 
water  sheds  contributing  to  St.  Louis  are  fairly  and  reasonably 
uniform,  barring  the  minor  fluctuations  which  always  occur  in 
such  death  rates  from  various  slight  causes,  but  the  dia- 
12916  gram  further  shows  that  at  and  from  the  year  1900  a 
very  large  number  of  deaths  were  added  to  the  normal 
deaths  upon  the  combined  water  shed  by  the  opening  of  the 
drainage  canal.  In  two  years  after  the  opening  of  the  drain- 
age canal  the ,  total  number  of  deaths  attributable  to  the 
water  supply  of  St.  Louis  had  been  more  than  doubled,  in 
marked  contrast  to  the  fairly  uniform  conditions  which  pre- 
vailed on  each  water  shed,  excluding  the  sanitary  district  of 
Chicago. 

Q.  And  is  that  evidenced  by  the  chart  which  you  have  re- 
ferred to? 

A.    I  think  it  is. 

Q,  Have  you  seen  the  charts  prepared  by  Professor  Mason, 
comparing  the  typhoid  conditions  in  Chicago  with  the  typhoid 
fever  conditions  in  St.  Louis  by  the  month? 

A.  I  have  not.  They  do  not  seem  to  me  to  be  among  the 
records  which  I  have  examined  in  this  case. 

Mr.  Jeffries:     I  want  to  state  in  this  connection  that  the 

charts  offered  in  evidence  by  Professor  Mason  and  about  which 

this  evidence  concerns  were  placed  in  the  hands  of  the 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        41 

12917  Commissioner  at  once  and  the  complainant  since  that 
time  lias  not  been  in  condition  to  examine  them  or  have 

•witnesses  examine  them. 

Mr.  Todd:  Q.  Have  you  compared  the  typhoid  condition 
in  the  city  of  Chicago  by  the  months  with  the  typhoid  condi- 
dition  in  the  city  of  St.  Louis  by  the  months? 

A.    I  have  not. 

Q.  Would  such  a  comparison,  allowing  thirty  days  inter- 
val between  Chicago  and  St.  Louis  to  intervene,  shed  any  light 
upon  the  question  as  to  whether  Chicago  has  any  effect  upon 
the  typhoid  conditions  in  St.  Louis  in  your  opinion? 

A.  I  should  be  afraid  that  it  would  induce  too  many  fluc- 
tuations and  variables  to  be  of  the  greatest  value,  I  should  pre- 
fer to  take  the  averages  for  the  year,  showing  in  a  more  marked 
manner  any  main  distinguishing  characteristics. 

Q.  Might  not  an  increase  in  the  typhoid  fever  in  the  city  of 
vSt.  Charles  be  expressed  in  the  typhoid  conditions  in  the  city 
of  St.  Louis? 

A.    Possibly. 

Q.  Might  not  an  increase  of  typhoid  fever  in  Kansas  City 
be  expressed  in  the  increase  in  typhoid  fever  in  the  city  of 

12918  St.  Louis,  taking  into  consideration  that  sixty-seven  per 
cent,  of  the  water  consumed  in  St.  Louis  is  Missouri  River 

^vater  ? 

A.  It  might  possibly  but  so  far  as  I  have  been  able  to  ob- 
serve it  does  not. 

Q.  Can  you  tell  whether  the  infection  that  afflicted  St. 
Louis  comes  from  St.  Paul,  Minneapolis  and  the  cities  on  the 
Mississippi  River,  the  cities  on  the  Missouri  river  or  the  cities 
on  the  Illinois  River? 

A.  I  think  when  conditions  are  marked  and  data  fairly  ade- 
quate that  it  is  possible  to  tell. 

Q.  Do  you  consider  that  any  of  the  typhoid  fevers  cases 
in  the  city  of  St.  Louis  is  due  to  Missouri  River  water? 

A.    There  is  always  that  possibility. 

Q.  What  is  your  opinion  as  to  whether  any  of  the  typhoid 
fever  in  St.  Louis  is  due  to  Missouri  River  water? 

A.  My  opinion  would  be  that  a  percentage  of  the  normal 
typhoid  deaths  in  St.  Louis  prior  to  1900  would  very  probably 


42  The  State  of  Missouri  vs. 

be  due  to  the  contamination  from  waters  of  the  Missouri  River. 
Q.    TVhat  cities  on  the  Missouri  River  would  you  attribute 
the  infection  to  1 

12919  A.     I  should  want  to  make  a  more  detailed  study  of  the 
case  before  venturing  an  opinion.    My  endeavor  has  been 

to-  study  the  problem  by  water  sheds  rather  than  cities,  except 
in  the  case  where  I  have  added  the  sanitary  district  of  Chi- 
cago. 

Q.  Would  you  regard  the  conditions  at  St.  Charles  as  con- 
tributing as  much  typhoid  as  the  city  of  Kansas  City,  to  the 
city  of  St.  Louis  ? 

A.  It  is  probable  that  it  may  have  an  equal  effect  upon 
the  normal  typhoid  deaths  in  St.  Louis. 

Q.  How  far  would  you  consider  the  city  of  St.  Charles  by 
water  in  point  of  time  from  the  St.  Louis  intake? 

A.    I  am  not  exactly  informed  as  to  that. 

Q.  The  distance  ha.s  been  estimated  by  the  river  at  ap- 
proximately forty  miles.  Are  you  acquainted  with  the  hydraulic 
conditions  of  the  Missouri  River? 

A.    To  some  extent. 

Q.  If  one  typhoid  fever  patient  could  create  the  epidemic 
at  Plymouth.  Massachusetts,  what  effect  in  your  opinion  would 
the  number  of  cases  of  typhoid  deaths  in  the  city  of  St.  Charles 
as  evidenced  by  the  statistics  which  you  have  studied,  have  upon 
the  water  supply  of  St.  Louis? 

A.    There  are  always  possibilities  of  contamination  from 

12920  unexpected  sources. 

Q.  Would  you  say  that  beyond  all  reasonable  doubt  the 
typhoid  fever  as  you  know  it  to  exist  in  the  city  of  St.  Charles 
is  not  responsible  for  the  great  proportion  of  the  typhoid  fever 
in  the  city  of  St.  Louis,  bearing  in  mind  what  you  know  about 
the  epidemic  at  Plymouth,  Pennsylvania,  and  of  other  epidemics 
that  you  have  studied  and  introduced  in  this  case? 

A.  I  should  be  inclined  to  think  from  my  diagram  that 
the  typhoid  deaths  in  St.  Charles  might  have  influenced  the  nor- 
mal typhoid  deaths  in  St.  Louis  prior  to  1900  to  some  unknown 
percentage. 

Q.    Since  1900? 

A.     I  should  be  disinclined  to  think  that  since  1900  the 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.         43 

typhoid  iii  St.  Charles  could  iiave  been  responsible  for  so 
marked  a  change  in  the  number  of  deaths  in  St.  Louis  from 
typhoid. 

Q.  .Does  the  number  of  people  afflicted  with  typhoid  fever 
m  a  given  city  depend  upon  the  number  of  people  that  have  ty- 
phoid fever  above  on  the  water  shed? 

A.  It  does  to  some  extent  when  you  are  considering  aver- 
ages over  long  periods. 

12921  Q.    How  do  you  account  for  the  Plymouth  epidemic  that 
was  due  to  one  typhoid  fever  case? 

A.    There  are  always  exceptional  occurrences  of  that  kind. 

Q.  Might  not  such  an  exceptional  occurrence  happen  be- 
tween St.  Charles  and  the  city  of  St.  Louis! 

A.    It  is  within  the  range  of  possibility. 

Q.  Being  in  the  range  of  possibility,  can  you  assert  that 
the  greater  proportion  of  typhoid  fever  in  the  city  of  St.  Louis 
can  not  be  attributed  to  such  a  possibility  beyond  all  reason- 
able doubts  and  to  a  moral  certainity? 

A.  In  the  absence  of  direct  proof  that  the  typhoid  deaths  in 
St.  Charles  have  been  responsible  for  the  rise  in  deaths  in  St. 
Louis,  we  are  obliged  to  proceed  on  the  theory  of  probability, 
and  the  theory  of  probability  would  indicate  that  the  prepon- 
derating number  of  deaths,  wherever  they  miay  be  found,  are  the 
responsible  cause,  therefore  I  would  be  disinclined  to  attribute 
(in  the  absence  of  direct  proof)  the  rise  in  the  typhoid  deaths 
in  St.  Louis  to  the  typhoid  deaths  in  St.  Charles. 

Q.  Do  you  employ  the  theory  of  probabilities  in  drawing 
your  conclusions  that  the  typhoid  increase  in  St.  Louis 

12922  is  due  to  Chicago? 

A.  Whenever  we  deal  with  a  problem  of  the  magnitude 
of  this  problem  and  its  complications,  we  are  obliged  as  one  of 
the  contributing  data  to  proceed  on  such  theory. 

Q.  And  that  theory  has  been  employed  by  you  in  giving 
your  opinions  on  the  effect  of  the  opening  of  the  canal  upon  the 
typhoid  condition  in  St<  Louis? 

A.     As  one  the  data  from  which  I  draw  my  conclusions. 

Q.  What  importance  do  you  attach  to  the  typhoid  condi- 
tions on  the  water  shed  of  the  Missouri  River?' 

A.     The  importance  that  is  shown  by  the  plotting  of  their 


44  The  State  of  Missouri  vs. 

deaths  upon  this  diagram  in  its  relation  to  the  deaths  from  other 
sources. 

Q.  Anybody  could  plot  those  deaths  on  a  diagram  could 
they  not  ? 

A.  Well,  they  might  not  always  be  able  to  accomplish  that 
in  such  a  way  that  they  would  bring  clearly  out  the  facts. 

Q.  But  my  question  is,  what  importance  do  you  attach  re- 
gardless of  the  Diagram  to  the  number  of  cases  of  typhoid  fever 
on  the  water  shed  of  the  Missouri  Elver  as  affecting  the 

12923  sanitary  quality  of  that  river? 

A.  I  should  attach  this  importance,  that  I  observe  that 
the  typhoid  deaths  on  the  Missouri  water  shed,  all  things  con- 
sidered, have  been  fairly  uniform  for  the  whole  period  shown, 
and  therefore  whatever  percentage  of  contributory  infection  the 
Missouri  water  shed  may  have  produced  prior  to  1900,  I  should 
be  inclined  to  attribute  in  equal  degree  to  the  period  since  1900. 

Q.  Do  you  regard  the  water  of  the  Missouri  River  in  its 
raw  state  as  a  safe  drinking  water  for  drinking  and  domestic- 
purposes  ? 

A.    I  do  not. 

Q.  As  treated  by  the  settling  basins  of  St.  Louis,  do  you 
regard  it  as  a  safe  drinking  water  for  drinking  and  domestic 
purposes  ? 

A.  I  should  say  that  it  has  in  all  probability  been  greatly 
improved  in  its  general  character. 

Q.  Is  it  not  a  fact  that  the  water  of  the  Missouri  River 
has  been  deteriorating  as  a  safe  drinking  water  for  the  last 
twenty-five  years,  and  each  year  more  so  1 

A.  I  think  that  may  be  safely  assumed  and  the  same  is 
probably  true  perhaps  of  all  our  western  rivers. 

12924  Q.    Do  you  regard  the  Mississippi  River  above  Graf  toil 
as  a  safe  drinking  water? 

A.    I  do  not. 

Q.  Do  you  regard  the  water  of  the  Illinois,  Mississippi  and 
Missouri  Rivers,  assuming  that  the  sanitary  district  of  Chicago 
ivas  eliminated,  and  treated  as  it  is  treated  in  the  settling  basins 
at  St.  Louis,  as  a  safe  drinking  water  to  be  used  by  a  city  of 
800,000  inhabitants,  such  as  St.  Louis  is,  as  it  is  at  present  used? 

A.  I  do  not  regard  it  entirely  so. 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        45 

Q.  If  you  were  selected  as  a  sanitary  egineer  or  a  hydraulic 
engineer  to  pass  upon  the  quality  of  the  water  of  the  Mississippi 
Biver,  a  mixture  of  Missouri,  Mississippi  and  Illinois  River 
water,  excluding  the  sanitary  district  of  Chicago,  treated  as  it 
is  now  treated,  would  you  recommend  it  as  a  safe  drinking 
water,  free  from  typhoid  infection! 

A.     I  should  not  like  to  so  recommend  it. 

Q.  What  w^ere  the  discharges  of  the  Illinois  River  at  the 
time  that  Randolph  made  his  iloat  experiments? 

A.     I  was  not  able  to  discover.    I  believe  Mr.  Randolph 
32925  gave  some  gaugings  at  Peru  and  gauge  readings  at  La 
Salle,  but  as  I  have  no  data  for  these  cross  sections,  I  am 
unable  to  determine  what  the  stage  was  in  terms  of  the  dis- 
charge. 

Q.  Was  it  at  high,  low,  average,  mean  or  below  mean  flow 
of  the  Illinois  River? 

A.  If  I  were  obliged  to  determine  from  such  evidence  as  I 
am  able. to  derive  from  his  testimony,  knowing  that  the  time 
when  the  floats  were  run,  was  in  the  month  of  July,  and  know- 
ing that  the  total  time  of  transit  in  comparison  with  Professor 
Van  Ornum  was  as  10  is  to  15,  I  should  be  inclined  to  judge  that 
the  stage  at  which  Mr.  Randolph's  experiments  were  taken  were- 
the  average  low  waters  of  mid  summer. 

Q.  If  you  do  not  know  the  stages  of  the  river  and  its  floTv  ^ 
how  are  you  able  to  give  that  opinion? 

A.  I  do  not  think  that  that  opinion  is  as  valuable  as  it 
would  be  if  I  did  know  the  exact  stages  of  the  flow. 

Q.  It  is  more  in  the  nature  of  a  guess  than  an  opinion  based 
upon  scientific  knowledge? 

A.    It  is  an  intelligent  guess. 

Q.    Did  you  ever  measure  the  current  from  the  Bear  Trap 
12926  dam  to  Lake  Joliet  with  floats  yourself? 
A.    I  believe  not  personally. 

Q.  Do  you  know  what  the  fall  is  from  the  Bear  Trap  dam 
to  Lake  Joliet? 

A.    Yes  sir. 

Q.  Knowing  the  fall  and  the  volume  of  water,  can  you 
figure  the  velocity  of  flow? 

A.    Yes  sir. 


46  The  State  of  Missouri  vs. 

Q.    Can  that  be  accurately  ascertained  by  that  method  ? 

A.    Not  as  accurately  as  it  could  by  the  floats. 

Q.    Did  you  have  it  done? 

A.     No  sir. 

Q.    With  floats? 

A.     No  sir. 

Q.  When  you  corrected  Professor  Van  Ornum's  time,  what 
method  did  you  employ  in  doing  it? 

A.  I  calculated  the  mean  velocity  by  the  cross-section  and 
rail  and  deducted  the  surface  velocity  by  dividing  by  .8. 

Q.  Is  there  a  better  method  than  floats  such  as  Professor 
Van  Ornuni  used  ? 

A.  There  would  not  be  if  the  same  stages  were  considered, 

12927  but  it  is  impossible  to  predicate  the  surface  velocity  at 
another  stage  from  the  float  experiments  of  Professor  Van 

Ornum,  with  any  very  great  exactness.  I  might  say  however 
that  I  used  the  speeds  found  by  Professor  Van  Ornum  for  the 
lower  stage  as  a  check  upon  the  calculations  which  I  made  for 
the  slightly  higher  stage  which  I  got. 

Q.  In  figuring  out  the  average  time  between  Chicago  and 
bt.  Lonis,  what  conclusions  did  you  come  to? 

A.  That  at  most  stages  of  the  river  uninfluenced  by  fi 
LU?  any  kind,  the  time  of  passage  of  the  pollution  vehicle  would 
be  in  the  neighborhood  of  the  float  experiments,  as  determined 
by  Mr.  Randolph  or  thereabouts,  but  not  reduced  to  mean  ve- 
locity, and  that  in  times  of  slight  or  medium  rises,  the  time  of 
passage  of  the  pollution  vehicle  would  be  aparently  in  accord- 
ance with  the  experiment  of  Professor  Van  Ornum,  and  that 
in  time  of  very  great  floods,  such  as  occurred  in  1902,  and  T 
believe  in  1888,  and  at  one  or  two  other  times  in  my  recollection, 
the  time  of  passage  might  be  reduced  to  eight  days  or  less. 

Q.     In  the  times  of  flood  there  would  be  greater  dilution 
would  there  not? 

12928  A.    Yes  sir. 

Q.  And  dilution  minimizes  danger  from  infection,  does 
it  not? 

A.  Not  altogether;  it  increases  the  longevity  of  the  typhoid 
germ. 

Q.     But  is  disseminates  them  in  a  greater  body  of  water 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.         17 

thereby  diminishing  on  the  theory  of  probability,  the  danger 
1'rom  infection  does  it  not? 

A.    I  should  think  that  would  be  a  fair  statement,  yes  sir. 

Q.  In  figuring  on  Mr.  Hering 's  chart  that  is  introduced  in 
evidence,  did  that  chart  show  a  population  of  13,000  people 
above  the  intake  tower? 

A.  I  have  not  seen  the  original  chart  that  Mr.  Hering  pro- 
duced but  a  zinc  etching  which  has  been  reduced  in  size,  so  that 
it  is  difficult  to  determine  what  the  actual  figures  might  be 
from  the  scale.  I  have,  however,  relied  upon  the  statement  of 
Mr.  Crane,  who  prepared  the  chart,  with  reference  to  those 
figures. 

Q.  By  the  method  that  you  employed  on  the  Illinois  end 
of  this  chart,  applying  that  same  method  to  the  Missouri  and 
Mississippi  Rivers,  will  you  state  what  the  results  show? 
1_!J»29  A.  I  have  not  undertaken  to  reduce  the  Missouri  and  Mis- 
sissippi Rivers  to  terms  of  .typhoid  pollution  at  St.  Louh 
in  the  manner  shown  by  Mr.  Hering. 

Q.    Why? 

A.    Because  I  did  not  deem  them  pertinent  to  this  inquiry. 

Q.  The  chart  which  Mr.  Hering  introduced  in  evidence 
allowed  a  comparison  between  the  conditions  that  obtained  on 
the  Illinois,  Mississippi  and  Missouri  Rivers,  based  upon  Mill's 
experiment,  did  it  not? 

Mr.  Jeffries :  Object  to  the  question  for  the  reason  that  this 
inquiry  is  not  to  determine  the  extent  of  the  pollution  and  the 
infection  of  the  Mississippi  River  above  Grafton  and  the  Mis- 
souri River,  but  that  the  inquiry  is  directed  solely  to  the  effect 
that  the  sewage  discharged  from  the  city  of  Chicago  has  upon 
the  waters  of  the  Illinois  River  and  consequently  upon  the  waters 
of  the  Mississippi  River  below  Grafton. 

A.    Yes  sir. 

Mr.  Todd:  Q.  If  you  had  carried  out  the  comparison  con- 
templated in  the  chart  introduced  by  Mr.  Hering,  would  the  pol- 
lution from  the  Illinois  River  be  as  great  as  the  pollution 
12930  from  the  Mississippi  and  the  Missouri  Rivers,  figured  in 
the  same  manner  that  you  have  figured  the  chart  which 
you  introduced? 

A.     I  am  not  able  to  say,  not  having  worked  out  the  data. 


48  The  State  of  Missouri  vs. 

Q.  In  order  to  make  a  comparison  between  your  method  of 
calculation  and  the  method  employed  by  Mr.  Hering,  do  you  not 
think  it  would  have  been  more  accurate  to  have  carried  out  your 
charts  for  the  three  rivers  instead  of  one? 

Mr.  Jeffries:  I  object  to  the  question  for  the  reason  that  it 
is  not  competent  evidence  in  this  case  to  make  comparison  be- 
tween the  relative  pollutions  of  the  three  rivers,  the  question 
involved  in  this  case  being  as  to  the  effect  of  the  sewage  dis- 
charges from  the  city  of  Chicago  upon  the  Illinois  River  and 
Mississippi  River  below  Graf  ton,  and  for  the  further  reason  that 
the  chart  introduced  in  evidence  by  this  witness  based  upon 
the  chart  of  Mr.  He  ring,  which  was  prepared  by  Mr.  Crane,  was 
not  introduced  for  the  purpose  of  showing  a  comparison  between 
the  pollutions  of  the  three  rivers,  but  for  the  purpose  of  show- 
ing the  effects  of  the  sewage  of  Chicago  upon  the  waters  of  the 
Mississippi  River  be]ow  Graf  ton. 

Mr.  Todd:     In  reply  will  state  that  the  chart  speaks  for 
itself  and  shows  the  opposite  of  what  the  counsel  con- 
12931  tends. 

Q.    Question  read. 
A.    I  do  not  see  how  it  could. 

Mr.  Todd:  Q.  In  the  chart  which  you  introduced,  com- 
puted upon  the  method  which  you  adopted,  I  believe  you  stated 
that  at  a  maximum  flow  in  the  Illinois  River,  the  pollution  at 
the  intake  tower  of  the  chain  of  rocks  was  equal  to  an  infection 
from  a  population  of  960,000  people.  Is  that  correct? 

A.  I  think  I  stated  that  the  method  of  Mr.  Hering,  worked 
out  with  the  corrections  which  I  have  suggested,  would  indicate 
that. 

Q.  Did  you  not  understand  Mr.  Hering 's  chart  to  be  for 
the  purpose  of  showing  the  relative  pollutions  of  the  three  rivers 
with  a  ratio  of  13  to  97  and  106,  whether  expressed  in  people  or 
otherwise? 

A.  I  understood  that  that  was  one  of  the  facts  which  he 
endeavored  to  bring  out,  but  I  also  understood  from  the  study 
of  his  chart  that  he  was  endeavoring  to  bring  out  as  well  the 
probable  amount  of  pollution  which  would  reach  the  intake  at 
the  chain  of  rocks  from  the  sanitary  district  of  Chicago,  based 
upon  the  experiments  of  Hiram  F.  Mills  and  the  float  experi- 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.        49 

merits  OL  Air.  Isham  Randolph. 

12932  Q.    You  did  not  understand  his  testimony  and  the  chart 
to  mean  that  there  was  a  city  of  13,000  people  dumping 

sewage  into  the  Mississippi  River  at  the  intake! 

A.  I  took  it  that  that  was  the  practical  effect  of  his  rea- 
soning. 

Q.  And  under  your  interpretation  of  the  chart,  supple- 
mented by  your  method  of  calculation,  there  would  be,  at  maxi- 
mum time,  a  population  of  96,000  people? 

A.    There  would  be. 

Q.  In  the  testimony  that  you  have  given  when  filter  plants 
have  been  in  operation,  and  the  cities  using  such  filter  plants 
have  been  the  victims  of  a  typhoid  fever  epidemic  through  the 
mismanagement  or  other  cause  of  the  plants,  are  any  of  those 
plants  to  which  you  refer  owned  and  operated  by  the  munici- 
pality itself  or  by  private  water  companies!? 

A.     They  are  about  equally  divided  between  the  two. 

Q.  How  many  of  these  epidemics  were  due  to  shutting  down 
of  the  filters  and  turning  in  the  raw  water  to  the  water  supply 
of  the  people? 

A.     I  think  two. 
Q.    Which  ones? 

12933  A.    Butler,  Pa,,  and  Beaver  Falls,  Pa, 

Q.  That  was  not  the  cause  then  of  the  filter  plant  as 
much  as  the  carelessness  of  the  water  company? 

A.  Well,  it  was  the  fault  of  the  filter  plant  to  adequately 
protect  the  water  supply  through  the  carelessness  of  the  employe 
connected  with  it. 

Q.  In  the  matter  of  the  Butler  Company  do  you  know 
whether  it  was  a  question  of  the  employes  or  the  question  of 
the  management  that  took  that  filter  plant  out  of  operation  and 
turned  the  raw  water  in? 

A.  I  think  it  was,  in  that  case,  the  question  of  the  manage- 
ment. 

Q.  Are  you  familiar  with  the  causes  that  led  to  the  epi- 
demic at  Butler? 

A.    Somewhat. 


A-4 


50  The  State  of  Missouri  rs. 

Q.  In  the  case  at  Beaver  Falls  the  same  thing  is  true  is 
It  not? 

A.     I  should  say  that  it  was. 

Q.  What  is  the  cause  of  greatest  expense  in  constucting  a 
filter,  matters  in  suspension  or  infection? 

A.  That  will  depend  very  much  upon  the  kind  of  water  and 
its  amount  of  pollution  that  is  to  be  dealth  with. 

12934  In  a  turbid  water  free  from  typhoid  pollution,  the  tur- 
bidity will  undobutedly  be  the  cause  of  the  greatest  ex- 
pense, but  in  a  water  comparatively  clear,  or  clear  most  of  the 
time,  but  subjected  to  typhoid  infection,  the  infection  will  un- 
doubtedly be  the  greatest  cause  of  expense. 

Q.  Which  would  it  cost  the  most  to  filter,  the  Missouri 
Mississippi  or  the  Illinois  River  water? 

A.  Based  on  turbidity  the  Missouri  River  water.  Based  on 
typhoid  infection  the  Illinois  River  below  the  sanitary  district 
i>f  Chicago. 

Q.    I  mean  at  Graf  ton? 

A.  I  should  say  at  Grafton  the  typhoid  infection  would  be 
at  least  equal  in  cost  to  the  turbidity. 

Q.     The  Mississippi? 

A.  For  the  Mississippi  River  I  should  think  the  cost  would 
•be  about  equal  for  both  turbidity  and  typhoid  infection. 

Q.  Would  the  cost  of  the  Mississippi  be  greater  or  less  than 
that  of  the  Illinois? 

A.  It  would  be  greater  for  turbidity  and  less  for  typhoid 
infection. 

Q.    In  the  general  cost  of  filtering  the  two  rivers  taking 

12935  every  thing  into  consideration  for  an  equal  sized  plant, 
would  it  cost  any  more  to  filter  the  Illinois  River  at  Graf- 
ton  than  it  would  the  Mississippi  at  Grafton? 

Mr.  Jeffries :  I  object  to  the  question  for  the  reason  that  the 
question  assumes  that  the  turbidity  of  the  two*  rivers  is  the  same 
and  that  while  increased  turbidity  might  to  some  extent  increase 
the  cost  of  the  construction  as  well  as  the  operation,  but  inas- 
much as  the  cost  of  the  construction  and  operation  of  a  given 
plant  for  a  given  river  is  determined  upon  the  question  of  tur- 
bidity and  the  well  known  and  probable  existence  of  infect ous 
material,  that  bv  reason  of  the  introduction  of  the  additional  in- 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.         51 

fectous  matt-rial  t'voin  the  Illinois  Elver,  the  cost  might  or  might 
not  be  greater,  and  therein  lies  the  impropriety  of  the  question, 
and  for  that  reason  the  question  is  misleading  and  does  not  con- 
tain sufficient  facts  upon  which  to  base  an  intelligent  and  rea- 
sonable answer. 

Q.    Question  read. 

A.  I  should  say  that  it  would  for  the  reason  that  in  filter- 
ing the  Illinois  River  at  Graf  ton  we  are  obliged  at  first  to  pro- 
vide for  the  cost  of  removing  the  turbidity  which,  while 

12936  it  is  less  than' the  turbidity  of  the  Mississippi  is  neverthe- 
less very  great  at  certain  seasons  of  the  year,  and  in  ad- 
dition to  this  question  to  provide   for  the   cost   of  protection 
against  typhoid  pollution  which  in  my  opinion  would  be  greater 
than  in  the  case  of  the  Mississippi  River. 

Mr.  Todd:  Q.  You  would  recommend  filtration  for  the 
water  supply  of  the  city  of  St.  Louis  would  you  not? 

A.     In  any  event. 

Q.  If  the  sanitary  district  of  Chicago  should  be  eliminated, 
you  would  still  recommend  a,  filtration  system  for  the  water  of 
the  city  of  St.  Louis  would  you  not? 

A.     I  would. 

Q.  When  in  the  employment  of  men  to  supervise  and  at- 
tend a  filter  plant  of  that  kind  you  wo-uld  get  the  highest  skill, 
would  you  not? 

A.     Yes  sir,  reasonably  so. 

Q.  If  the  sanitary  district  of  Chicago  should  turn  its  sew- 
age in,  you  would  still  recommend  the  filtration  system  would 
yon  not? 

12937  A.    Yes  sir,  but  I  should  recommend  at  least  a  double  fil- 
tration system,  preceded  by  successive  stages  of  sedi- 
mentation or  some  additional  form  of  protection  to  that  which 
L  would  suggest  for  waters  from  the  water  shed,  excluding  the 
sanitary  district  of  Chicago. 

Q.  Would  you  employ  any  less  competent  men  to*  operate 
the  filter  plant  with  the  sewage  of  Chicago  eliminated,  than 
you  would  with  it  present? 

A.  I  am  inclined  to  think  I  should  want  a  very  high  grade 
of  intelligence  at  the  head  of  such  a  plant,  if  it  were  going  to 
provide  against  typhoid  contamination  as  against  perhaps  less 


^'2  The  State  of  Missouri  vs. 

expensive  treating  if  it  were  going  to  deal  with  turbid  waters  or 
waters  of  very  rare  pollution. 

Q.  "Where  would  you  get  the  men  from  to  operate  such  n 
plant  that  had  experience  in  a  filter  system  the  size  that  wo-uki 
be  needed  in  the  city  of  St.  Louis ! 

A.  Albany,  Berlin,  London,  or  men  in  this  country  who  had 
given,  those  large  filters  close  study  and  attention. 

Q.  Would  you  put  men  in  charge  of  a  filter  p}ant  with  less 
'  capability  and  experience  if  the  sewage  of  Chicago  was 

12938  eliminated  than  you  would  if  it  were  present! 

A.  Not  to  any  very  marked  degree.  I  should  think  I 
would  be  a  little  more  cautious  and  would  recommend  a  little 
greater  expense,  but  I  do  not  think  that  the  difference  in  the 
cost  of  filtration  would  be  very  much  affected  by  that  particular 
item. 

Q.  In  the  construction  of  the  filtration  plant  at  Philadelphia 
—which  is  the  largest  in  the  United  States  is  it  not! 

A.     Yes  sir. 

Q.  Do  you  know  whether  there  is  any  element  of  cost  en- 
tered into  in  that  plant  in  order  to  guard  against  infection! 

A.  Yes,  I  think  the  final  filters  can  be  properly  so  con- 
sidered. 

Q.  If  John  "W.  Hill  who  was  constructing  that  plant  should 
testify  that  infection  was  no  element  of  cost  in  the  operation  and 
installation  of  that  plant,  would  his  opinion  have  any  weight 
with  you! 

A.    I  think  I  should  be  disinclined  to  agree  with  him. 

Q.  Have  you  constructed  any  filter  plant  wherein  you  have 
made  additional  cost  to  guard  against  infection! 

12939  A.    I  do  not  think  I  have  personally,  with  this  exception 
that  I  have  provided  for  the  filtration  of  sewage  as  well 

as  the  purification  of  water  in  a  city  deriving  its  water  supply 
from  the  same  source  into  which  it  emptied  the  sewage. 

Q.  Have  you  designed  any  filter  plant  where  the  question 
of  infection  was  eliminated,  in  the  purification  of  water! 

A.  I  think  I  have  not  designed  any  plant  where  it  was 
wholly  eliminated.  In  some  of  the  places  it  was  a  very  minor 
consideration? 

Q.    Mr.  Alvord,  Mr.  Hering,  in  his  testimony,    was-    asked 


The  State  of  Illinois  and  the  Sanitary  District  of  Chicago.         53 

this  question:  "In  the  construction  of  a  filtration  plant,  is  it 
not  a  fact  that  sanitary  engineers  take  into  consideration  the 
extent  of  the  infecting  material  discharged  into  a  stream  above 
in  determining  the  character  of  the  plant  to  be  recommended/' 
and  in  answer  thereto  said,  "We  do  take  that  fact  into  considera- 
tion." The  further  question  was  asked,  "In  considering  the 
construction  of  a  filtration  plant  for  the  filtering  of  a  water 
supply  for  a  city  which  is  taken  from  a  running  stream,  sani- 
tary scientists  would  recommend  the  use  of  a  larger  quantity  of 
sand,  if  it  be  that  character  of  a  plant,  per  100,000  population 
than  if  such  water  be  subjected  to  the  sewerage  of  a  city  of  1,000 
population  would  they  not/'  and  in  answer  thereto,  Mr. 

12945  Hering  said:  "The  population  would  cut  no  figure  in  my 
mind.    We  would  under  peculiar  conditions  possibly  re- 
commend one  system  of  filtration  for  a  highly  polluted  water, 
while  we  would  be  satisfied  with  another  system  of  filtration  in 
a  very  slightly  polluted  water."    I  will  ask  you  if  in  the  con- 
struction and  operation  of  a  filtration  plant,  sanitary  engineers 
do  not  take  into  consideration  the  fact  that  when  water  is1  highly 
polluted  with  ijifected  material  that  more  complex  construction 
must  be  obtained  and  that  complex  construction  or  plant  more 
perfectly  marked  and  that  by  reason  of  such  superior  construc- 
tion and  cautious  maintenance  a  municipality    would    be    re- 
quired to  employ  more  efficient  men  and  be  more  cautious  and 
observant  as  to  the  operation  of  the  plant,  and  that  this  fact  is 
well  recognized  by  sanitary  engineers  and  by  the  officers  of  the 
municipalities  where  filtration  plants  are  being  constructed. 

Mr.  Todd:  Object  to  the  question  as  not  re-direct  examina- 
tion, and  as  leading.  It  is  not  rebuttal  and  therefore  incom- 
petent, irrelevant  and  immaterial. 

A.    I  think  this  is  a  fact  well  recognized. 

12946  Mr.  Jeffries:     Q.    Is  it  not  a  fact  that  as  the  infection 
material  is  increased  in  a  running  stream  that  is  being 

filtered  that  it  is  recognized  by  all  sanitary  engineers  that  the 
construction  must  be  more  perfect,  of  a  higher  grade,  and  that 
the  equipment,  the  maintenance  and  the  character  of  the  em- 
ployes more  efficient? 

Mr.  Todd:  Object  to  the  question  as  to  the  previous  ques- 
tion. 


54  The  State  of  Missouri  vs. 

A.     I  think  that  it  is. 

Mr.  Todd:  Move  to  strike  out  the  answer  for  the  reasons 
heretofore  given. 

Mr.  Jeffries:  Q.  In  the  filtration  of  a  given  water  when 
the  filtration  plant  has  been  constructed,  assume  that  subse- 
quent to  the  construction  of  this  filtration  plant  the  sewage 
disposal  of  a  large  and  populous  city  be  so  disposed  as  to  find 
its  way,  or  the  deleterious  substances  that  are  found  therein* 
into  the  waters  of  that  river  above  the  filtration  plant,  state 
whether  or  not  in  your  opinion  more  precaution  and  greater  care 
should  afterwards  be  maintained  in  the  operation  of  that 

12947  plant? 

Mr.  Torld:  Object  to  the  question  for  the  same  reason 
as  heretofore  stated. 

A.    In  my  opinion  they  should. 

Mr.  Todd:  Q.  If  you  were  going  to  construct  a  filtration 
plant  for  the  city  of  St.  Louis  would  you  construct  it  less  stable 
and  durable  and  with  infected  material  to  filter  in  order  to  filter 
the  water  of  the  Mississippi  River  with  the  sewage  of  the  drain- 
age canal  eliminated  than  you  would  if  that  sewage  was  in  it? 

A.  I  do  not  think  that  the  stability  or  permanency  would 
enter  into  the  question.  I  think  it  would  be  simply  a  question 
of  the  number  of  stages  into  which  the  purification  would  be 
divided,  and  the  resulting  complexity  of  the  plant  as  a  whole. 

Q.  But  in  answer  to  one  of  Mr.  Jeffries'  questions  you 
stated  that  it  would  not  require  the  same  high  skill  in  the  put- 
ting up  of  the  plant  under  the  one  condition  as  the  other.  As 
a  matter  of  fact  building  a  filter  plant  to  filter  the  amount  of 
Water  necessary  for  the  city  of  St.  Louis,  you  would  employ  the 
very  best  material  and  the  highest  skill  obtainable  in 

12948  such  a  plant  under  either  condition  would  you  not? 

A.  So  far  as  the  actual  construction  was  concerned,  yes. 
But  in  so  far  as  the  complex  arrangement  of  the  plant  is  con- 
cerned, no. 

Q.  In  the  employment  of  the  men  to  handle  the  filter  that 
would  be  a  matter  that  would  be  left  to  the  municipality  would 
it  not? 

A.     I  presume  it  would. 

JOHN  W.  ALYORD. 
ADJOURNED  until  2:30  P.  M.,  Mav  26.  1904. 


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